In the 1940 case of American United Mutual Life Insurance Co. v. City of Avon Park, Florida, the Supreme Court ruled in favor of the city and upheld its right to tax property owned by a foreign corporation within its jurisdiction. The insurance company had purchased land for investment purposes and argued that it should be exempt from taxation because it was not using or profiting from the property at that time; however, this argument was rejected by both lower courts and eventually by the Supreme Court as well. The court held that all real estate within a state is subject to taxation unless expressly exempted under state law - regardless if it's being used or not - thereby affirming states' rights over corporate interests in matters concerning local taxes.

The dissenting opinion in the case of American United Mutual Life Insurance Co. v. City of Avon Park, Florida disagreed with the majority's ruling that a municipal corporation could not be sued without its consent due to sovereign immunity. The dissent argued that this principle was outdated and should no longer apply, especially in cases where a municipality engaged in commercial activities like issuing bonds for public improvements. They contended that when municipalities enter into business relationships, they should be held accountable just like any other entity or individual would be under contract law. This accountability includes being subject to lawsuits if they fail to meet their obligations as agreed upon in contracts or agreements made with others parties such as bondholders.