In Stewart v. Jefferson Police Jury, the Supreme Court of the United States was asked to decide whether a Louisiana statute that allowed a police jury to levy a tax on the property of a non-resident was constitutional. The plaintiff, Stewart, was a non-resident of Louisiana who owned property in the state. The police jury had levied a tax on his property, and he argued that the statute was unconstitutional because it violated the Due Process Clause of the Fourteenth Amendment. The Supreme Court held that the statute was constitutional. The Court reasoned that the Due Process Clause did not prohibit a state from taxing the property of a non-resident, as long as the tax was applied in a reasonable manner. The Court noted that the statute in question provided for notice to the non-resident taxpayer and an opportunity to be heard before the tax was imposed. The Court concluded that these provisions were sufficient to satisfy the requirements of due process. Therefore, the Supreme Court held that the Louisiana statute was constitutional and that the police jury was entitled to levy the tax on Stewart's property.

Justice Field delivered the dissenting opinion in Stewart v. Jefferson Police Jury, arguing that the majority had erred by failing to recognize a distinction between public and private property rights. He argued that while it was true that state governments could not interfere with an individual's right to use their own land as they saw fit, this did not mean that states were prohibited from regulating how individuals used public lands. In his view, Louisiana had acted within its authority when it passed legislation preventing citizens from using certain areas of navigable waters for oyster harvesting without first obtaining permission from local authorities. Furthermore, he noted that such regulations were necessary in order to protect both the environment and other users of these waterways who may be affected by any changes made on them without proper oversight or regulation. Ultimately, Justice Field concluded that Louisiana's law was valid and should have been upheld by the Court instead of being struck down as unconstitutional.