In Wyman, Treasurer, v. Halstead, Administrator, the Supreme Court of the United States was asked to decide whether a state could tax the estate of a deceased person who was a resident of another state. The case arose when the administrator of the estate of a deceased person, who was a resident of New York, attempted to collect a tax from the estate in the state of Connecticut. The administrator argued that the tax was unconstitutional because it violated the privileges and immunities clause of the Fourteenth Amendment. The Supreme Court held that the tax was constitutional and that the state of Connecticut had the right to impose the tax. The Court reasoned that the privileges and immunities clause of the Fourteenth Amendment did not apply to the estate of a deceased person, and that the state of Connecticut had the right to impose the tax. The Court also held that the tax was not a violation of the due process clause of the Fourteenth Amendment, as the tax was imposed in a reasonable manner and was not arbitrary or oppressive. In conclusion, the Supreme Court held that the state of Connecticut had the right to impose the tax on the estate of a deceased person who was a resident of another state. The Court reasoned that the privileges and immunities clause of the Fourteenth Amendment did not apply to the estate of a deceased person, and that the tax was imposed in a reasonable manner and was not arbitrary or oppressive.

In Wyman, Treasurer v. Halstead, Administrator the Supreme Court was asked to decide whether a state could tax the estate of a non-resident decedent who owned real property in that state at the time of their death. The majority opinion held that such taxation was permissible under existing law and precedent. However, Justice Field dissented from this decision on two grounds: firstly, he argued that it violated due process as guaranteed by the Fourteenth Amendment; secondly, he contended that it contravened Article IV Section 2 of the Constitution which states “the citizens of each State shall be entitled to all Privileges and Immunities of Citizens in several States”. In his view these provisions prohibited any discrimination between residents and non-residents when it came to taxation matters. He concluded by stating “I am unable to assent to an interpretation which would permit one State…to impose upon its own citizens burdens not imposed upon those coming from other States”