People of New York v. Coe Manufacturing Co.

The opinion of the court was delivered by

Lloyd, J.

The State of New York recovered a judgment in the Supreme Court of that state for a franchise tax imposed by its laws upon foreign corporations doing business within the state. On that judgment the present action was instituted.

The answer filed here by the defendant, a corporation of this state, was to the effect that the New York court was without jurisdiction; that the statute did not contemplate liability in personam,; that the State of New York was without power to levy the assessment or tax on property outside of that state; that it was…