The U.S. Supreme Court case Territory of Arizona at the Relation of Gaines, Tax Collector of Cochise County v. Copper Queen Consolidated Mining Company in 1913 revolved around a dispute over taxation on mining property owned by the defendant company in Cochise County, Arizona. The tax collector for the county claimed that certain improvements made to the land increased its value and should be taxed accordingly; however, these improvements were not physically located within Cochish County but rather extended into an adjacent county. The mining company argued against this claim stating that they shouldn't have to pay taxes on property outside their jurisdictional boundaries. The Supreme Court ruled in favor of Copper Queen Consolidated Mining Company stating that while it was true that improvements could increase taxable value, such increases must occur within territorial limits where taxing authority resides. Therefore, any enhancements or developments made outside those bounds cannot be considered when determining tax obligations.

In the dissenting opinion for the case of Territory of Arizona at the Relation of Gaines, Tax Collector of Cochise County v. Copper Queen Consolidated Mining Company, Justice Holmes argued that it was not within the jurisdiction or power of a federal court to interfere with state tax collection efforts unless there is clear evidence that such interference is necessary to prevent an irreparable injury. He contended that in this particular case, no such evidence existed and thus he disagreed with the majority's decision to grant an injunction against Arizona's tax collector. Furthermore, he expressed concern over what he saw as a potential violation of states' rights by allowing federal courts too much authority in matters traditionally handled by state governments.