Wheeler v. Cloyd is a Supreme Court case from 1891 that dealt with the issue of whether a state could tax the income of a non-resident. The case was brought by a resident of the state of Missouri, who was being taxed on income he had earned in the state of Arkansas. The Supreme Court ruled in favor of the plaintiff, finding that the state of Missouri had no authority to tax the income of a non-resident. The Court held that the power to tax income was reserved to the state in which the income was earned, and that the state of Missouri had no authority to tax income earned in another state. The Court also held that the state of Missouri could not impose a tax on the income of a non-resident without violating the due process clause of the Fourteenth Amendment. This case established the principle that states cannot tax the income of non-residents, and it is still used today to protect the rights of non-residents from being taxed by states in which they do not reside.

In the Supreme Court case of Wheeler v. Cloyd, Justice Black delivered a dissenting opinion in which he argued that the majority’s decision was wrong and should be overturned. He believed that the court had erred by failing to consider whether or not there was an implied contract between Wheeler and Cloyd when they entered into their agreement for services rendered. According to Justice Black, if such an implied contract existed then it would have been enforceable under Alabama law as well as federal law since both parties were citizens of different states at the time of entering into said agreement. Furthermore, he argued that even if no explicit contract existed between them, then still there could have been some form of equitable relief granted due to unjust enrichment on behalf of one party over another based upon their actions prior to any dispute arising from this matter. In conclusion, Justice Black felt strongly that justice had not been served in this case and urged his fellow justices to reconsider their ruling accordingly so as to provide a more just outcome for all involved parties