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.

Justice Field delivered the dissenting opinion in this case. He argued that the majority's decision was contrary to established precedent and would lead to a dangerous expansion of federal power over state governments. He noted that Congress had never intended for its legislation, which granted exclusive jurisdiction over navigable waters to the United States, to be used as a means of regulating local matters such as water rights disputes between two states. Furthermore, he argued that if Congress could use this law as an excuse for intervening in these types of cases then it would open up all sorts of possibilities for further federal intervention into areas traditionally reserved solely for state control. Justice Field concluded by stating his belief that allowing such interference from Washington D.C., without clear authorization from Congress, would undermine both the Constitution and principles of dual sovereignty between states and nation-states enshrined within it.