Wisner v. Brown was a United States Supreme Court case that addressed the issue of whether a state could impose a tax on a non-resident's income from property located within the state. The case was brought by a non-resident of the state of New York, who owned property in the state and was subject to a tax on the income from that property. The non-resident 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 valid exercise of the state's power to tax. The Court noted that the tax was not discriminatory, as it applied equally to all non-residents, regardless of their state of residence. Furthermore, the Court held that the tax was not an undue burden on interstate commerce, as it was a reasonable exercise of the state's power to tax. In conclusion, the Supreme Court held that the tax imposed by the state of New York on the income of non-residents from property located within the state was constitutional. The Court found that the tax was not discriminatory and did not unduly burden interstate commerce.

Justice Field delivered the dissenting opinion in Wisner v. Brown, arguing that a state's power to regulate its own internal affairs should not be interfered with by the federal government. He argued that while Congress had authority over interstate commerce and foreign trade, it did not have any authority over intrastate commerce or local matters such as this case involving an Ohio statute which prohibited non-residents from engaging in certain professions within the state without first obtaining a license from the Secretary of State. Justice Field believed that since this was an issue concerning only one state, it should remain solely under their jurisdiction and control rather than being subject to interference by Congress or other states. He also noted how allowing each individual state to make decisions on these types of issues would help ensure uniformity among all states when dealing with similar matters instead of having them vary widely depending on what laws were passed at a federal level.