In the case of Arkansas Fuel Oil Co. v. Louisiana Ex Rel. Muslow, the U.S Supreme Court ruled in favor of Arkansas Fuel Oil Company, stating that a state cannot regulate or interfere with interstate commerce beyond its borders under the Commerce Clause of the Constitution. The State of Louisiana had attempted to prevent natural gas companies from transporting gas out-of-state unless they first met all local demand at a set price determined by state authorities. The court held this action as unconstitutional because it interfered with interstate commerce and violated federal law which has supremacy over state laws in matters related to interstate trade and business activities.

In the dissenting opinion for Arkansas Fuel Oil Co. v. Louisiana Ex Rel. Muslow, Justice Butler argued that the majority's decision was a violation of due process and equal protection under the Fourteenth Amendment. He contended that there was no substantial difference between interstate commerce in petroleum products and other commodities, thus making it unconstitutional to impose taxes on one but not others. Furthermore, he disagreed with the majority's assertion that this tax would not burden interstate commerce or discriminate against out-of-state businesses because it applied equally to all companies selling fuel oil within Louisiana regardless of their state of origin or operation location outside Louisiana borders.