In the case of State of Wisconsin v. Pelican Insurance Company, the Supreme Court of the United States was asked to decide whether the state of Wisconsin had the right to tax the income of a foreign insurance company. The insurance company, Pelican Insurance Company, was incorporated in Louisiana and had its principal place of business in that state. The company argued that it was not subject to taxation by the state of Wisconsin because it was a foreign corporation. The Supreme Court held that the state of Wisconsin had the right to tax the income of the foreign insurance company. The Court reasoned that the company was doing business in Wisconsin and was therefore subject to the state's taxing power. The Court noted that the company had agents in Wisconsin, was issuing policies in the state, and was receiving premiums from Wisconsin residents. The Court concluded that the company was doing business in the state and was therefore subject to taxation. The Court also held that the state of Wisconsin had the right to tax the income of the foreign insurance company even though it was incorporated in Louisiana. The Court reasoned that the company was doing business in Wisconsin and was therefore subject to the state's taxing power. The Court noted that the company had agents in Wisconsin, was issuing policies in the state, and was receiving premiums from Wisconsin residents. The Court concluded that the company was doing business in the state and was therefore subject to taxation.

In the case of State of Wisconsin v. Pelican Insurance Company, Justice Field delivered a dissenting opinion that argued against the majority's decision to reverse and remand the judgment from the Supreme Court of Wisconsin. He believed that it was not necessary for this court to review or revise any previous decisions made by state courts in order to determine whether an insurance company is liable for losses caused by fire on property located within its policy limits. Instead, he argued that such matters should be left up to those courts since they are more familiar with local laws and customs than federal judges would be. Furthermore, he noted that if there were any errors in their rulings then it could easily be corrected through appeals process without having this court intervene directly. In conclusion, Justice Field felt strongly about preserving states' rights when it comes to determining liability issues related to insurance policies as long as no constitutional questions are involved.