In the 1940 case of Beal v. Missouri Pacific Railroad Corp., the U.S Supreme Court ruled in favor of Missouri Pacific Railroad, stating that a Nebraska state law was unconstitutional. The law required railroads to maintain and operate depots at every town along their route with more than 100 residents. The court found this requirement to be an undue burden on interstate commerce, violating the Commerce Clause of the Constitution which gives Congress exclusive power over such matters. This decision reinforced federal supremacy over states in regulating interstate commerce and emphasized that states cannot impose regulations that interfere with or are contrary to federal laws.

The dissenting opinion in the case of Beal v. Missouri Pacific Railroad Corp., argued that the majority's decision to allow a state tax on interstate commerce was unconstitutional. The dissenters believed that this ruling violated the Commerce Clause of the Constitution, which gives Congress exclusive power over interstate commerce. They contended that allowing states to impose taxes on such activities would lead to an unfair and unworkable system where businesses engaged in interstate trade could be subjected to multiple layers of taxation from different jurisdictions. This, they argued, would create a significant burden on interstate commerce and potentially disrupt economic activity across state lines. Furthermore, they disagreed with the majority's interpretation of previous court decisions related to this issue, arguing instead for a more restrictive view towards state taxation powers over interstate business operations.