The Stewart v. People of the State of Michigan case in 1913 revolved around a dispute over property rights and taxation. The plaintiff, Stewart, argued that his property was being unfairly taxed by the state of Michigan due to an incorrect assessment value. He claimed that this violated his Fourteenth Amendment rights as it deprived him of his property without due process and equal protection under the law. However, the Supreme Court ruled against Stewart stating that he had not exhausted all available remedies at a local level before bringing forth this lawsuit to federal court. Therefore, they dismissed his claim for lack of jurisdiction because there were still potential solutions within Michigan's legal system which he could have pursued before escalating it to a national level.

In the dissenting opinion for Stewart v. People of the State of Michigan, Justice Holmes argued that there was no constitutional violation in this case. He stated that while it is true that a person cannot be compelled to incriminate themselves under the Fifth Amendment, he did not believe this protection extended to physical evidence such as fingerprints or photographs. In his view, these were not testimonial or communicative by nature and thus fell outside the scope of self-incrimination protections. Furthermore, he believed that even if they could be considered self-incriminating in some way, their use would still be permissible because they are obtained without any form of compulsion on part of law enforcement officers.