The American Seeding Machine Company v. Commonwealth of Kentucky case in 1914 revolved around the issue of taxation and interstate commerce. The American Seeding Machine Company, an Ohio-based corporation, had a branch office and warehouse in Louisville, Kentucky where it stored goods for sale. The state of Kentucky imposed taxes on these goods which the company contested arguing that this was an infringement on interstate commerce as per the U.S Constitution's Commerce Clause. However, the Supreme Court ruled against them stating that since they maintained a stock of goods within Kentucky's borders with intent to sell locally or otherwise distribute them from their Louisville location, those items were subject to local taxation without interfering with interstate commerce regulations. This decision upheld states' rights to tax property held by out-of-state corporations within their jurisdiction if such property is intended for local distribution or sale.

The dissenting opinion in the case of American Seeding Machine Company v. Commonwealth of Kentucky argued that the state's taxation method was unconstitutional as it violated due process and equal protection clauses. The justice contended that the tax imposed on corporations for their franchise to do business within Kentucky, calculated based on both in-state and out-of-state property, unfairly burdened interstate commerce. They believed this approach resulted in double taxation since companies were also taxed by states where their properties were physically located. This, they asserted, created an unjust disadvantage for businesses operating across multiple states compared to those only functioning within one state - a violation of equal protection rights under the Fourteenth Amendment. Furthermore, they held that taxing entities without providing them with corresponding benefits or protections constituted a breach of due process rights.