Sturges v. Carter, Treasurer was a United States Supreme Court case that addressed the issue of whether a state could impose a tax on the transfer of property upon the death of the owner. The case was brought by the executor of the estate of a deceased man, who had been assessed a tax by the state of New York on the transfer of the deceased's property. The executor argued that the tax was unconstitutional, as it violated the due process clause of the Fourteenth Amendment. The Supreme Court held that the tax was constitutional, as it was a reasonable exercise of the state's power to tax. The Court noted that the tax was not a direct tax, and that it was not so oppressive as to be unconstitutional. The Court also noted that the tax was not a violation of the due process clause, as it was not arbitrary or capricious. In conclusion, the Supreme Court held that the tax imposed by the state of New York on the transfer of property upon the death of the owner was constitutional, as it was a reasonable exercise of the state's power to tax. The Court noted that the tax was not a direct tax, and that it was not so oppressive as to be unconstitutional. The Court also noted that the tax was not a violation of the due process clause, as it was not arbitrary or capricious.

In Sturges v. Carter, Treasurer, the Supreme Court was tasked with determining whether a state law that imposed a tax on individuals who had previously been convicted of certain crimes violated the Constitution's Ex Post Facto Clause. The majority opinion held that it did not violate this clause because it was not considered to be punishment for past offenses and instead served as an exercise of taxation power by the state government. Justice Field dissented from this opinion and argued that while states have broad powers when it comes to taxation, they cannot impose taxes in such a way as to punish people for their prior criminal convictions. He further noted that if states were allowed to do so then there would be no limit on what kind of punishments could be imposed upon those already convicted or even those accused but not yet tried or found guilty of any crime. In his view, allowing such practices would undermine fundamental principles of justice and fairness enshrined in both federal and state constitutions which prohibit ex post facto laws from being enacted or enforced against citizens