In Alabama & Others v. Montague & Another, the Supreme Court of the United States was asked to decide whether a state could constitutionally impose a tax on the sale of goods imported from another state. The case arose when the state of Alabama attempted to impose a tax on goods imported from the state of Mississippi. The Supreme Court held that the tax was unconstitutional because it violated the Commerce Clause of the United States Constitution. The Supreme Court held that the tax was unconstitutional because it was a direct burden on interstate commerce. The Court reasoned that the tax was a form of protectionism, which was prohibited by the Commerce Clause. The Court also held that the tax was discriminatory because it only applied to goods imported from other states, and not to goods produced within the state. The Court concluded that the tax was unconstitutional because it violated the Commerce Clause of the United States Constitution. The Court held that the tax was a direct burden on interstate commerce and was discriminatory in nature. The Court also held that the tax was a form of protectionism, which was prohibited by the Commerce Clause. As a result, the Supreme Court held that the tax was unconstitutional and could not be imposed.

In the dissenting opinion of Alabama & Others v. Montague & Another, Justice Field argued that the majority had misapplied the law in this case and failed to consider a key precedent set by an earlier Supreme Court decision. He noted that in United States v. Bevans, 16 U.S., 3 Wheat 336, it was established that when two states have conflicting laws on a matter such as taxation or property rights, then federal courts must apply whichever state's law is more beneficial to citizens of both states - regardless of which state enacted it first or has jurisdiction over the land at issue. In this case involving taxes imposed by Alabama on lands located within its borders but owned by residents from Mississippi, Justice Field argued that since Mississippi did not impose any similar tax on these same lands (or indeed any other kind) then under Bevans' ruling Alabama should be barred from doing so either; thus he concluded his dissent with a call for reversal of the lower court's judgment against Montague and others who were being taxed unfairly according to him due to their status as non-residents of Alabama yet owners of land thereon.