Rufus Wheeler Peckham

“ The principle which renders void a statute providing for the personal liability of a nonresident to pay a tax of this nature is the same which prevents a state from taking jurisdiction through its courts, by virtue of any statute, over a nonresident not served with process within the state, to enforce a mere personal liability, and where no property of the nonresident has been seized or brought under the control of the court. ”

“ To enforce an assessment of such a nature against a nonresident, so far as his personal liability is concerned, would amount to the taking of property without due process of law, and would be a violation of the federal constitution. ”

“ No question of a federal nature claimed under the constitution of the United States can be said to have been made by the mere allegation 'that the amount of said tax is greater than the reasonable market value of said lots, whether considered singly or together, the assessment against each particular lot being greater in amount than the value of such particular lot, and the aggregate assessment being greater in amount than the reasonable market value of all of said lots taken together ”