In the 1929 case of Brinkerhoff-Faris Trust & Savings Company v. Hill, the U.S. Supreme Court ruled on a dispute involving taxation and banking laws in Missouri. The Brinkerhoff-Faris Trust & Savings Company had challenged an annual tax imposed by Henry County, arguing that it was unconstitutional as it violated their rights under the Fourteenth Amendment's due process clause and interfered with interstate commerce. However, the court upheld the county's right to impose this tax. Justice Oliver Wendell Holmes Jr., writing for a unanimous court, stated that while banks were involved in interstate commerce through loans and other transactions, they were not directly engaged in such activities themselves; thus they could be subject to state taxation without violating federal law or constitutionally protected rights.

In the dissenting opinion for Brinkerhoff-Faris Trust & Savings Company v. Hill, Justice Stone argued that the Missouri state law in question did not violate the Contract Clause of the U.S. Constitution as it was a valid exercise of police power to protect public welfare and interest. He contended that states have inherent authority to regulate banking practices within their jurisdiction, including setting reasonable limits on loan interest rates to prevent usury or excessive lending charges which could harm borrowers and destabilize financial markets. In his view, such regulatory measures do not impair contractual obligations but rather define and condition them according to societal needs and norms; they are part of an implicit understanding between contracting parties who must anticipate potential changes in relevant laws over time. Therefore, he disagreed with majority's ruling invalidating this law based on its retroactive application affecting existing contracts.