Wadsworth v. Warren was a United States Supreme Court case that dealt with the issue of whether a state could require a non-resident to pay a tax on the sale of real estate located within the state. The case was brought by a resident of Massachusetts, Wadsworth, who had sold a piece of real estate located in Rhode Island. Rhode Island had imposed a tax on the sale of the property, and Wadsworth argued that the tax was unconstitutional. The Supreme Court held that the tax was constitutional, and that states had the right to impose taxes on non-residents who sold real estate located within the state. The Court reasoned that the tax was a legitimate exercise of the state's power to regulate commerce, and that it did not violate the privileges and immunities clause of the Fourteenth Amendment. The Court also noted that the tax was not discriminatory, as it applied equally to all non-residents who sold real estate within the state. In conclusion, the Supreme Court held that the tax imposed by Rhode Island on the sale of real estate located within the state was constitutional, and that states had the right to impose such taxes on non-residents.

In the case of Wadsworth v. Warren, Justice Field delivered a dissenting opinion in which he argued that the majority had incorrectly interpreted the law and failed to consider relevant evidence. He noted that under California law, an executor was not required to file an inventory or account until after all debts were paid; however, in this case, it appeared as though some debts had been paid prior to filing such documents. Furthermore, Field argued that even if there was a violation of state law regarding filing requirements for inventories and accounts by Wadsworth (the executor), this did not necessarily mean that his actions should be considered fraudulent or voidable at common law. Rather than invalidating any transactions made by Wadsworth during his tenure as executor on these grounds alone, Field suggested further inquiry into whether fraud actually occurred before making such determinations. Ultimately then, while acknowledging potential violations of state laws governing fiduciary duties owed by an executor to beneficiaries under their will or trust agreement with them – Justice Field concluded that more information needed to be gathered before determining whether any action taken by Wadsworth constituted actual fraud against Warren (the beneficiary).