In Brown and Others v. The State of Maryland, the Supreme Court ruled that a state law requiring non-residents to pay taxes on goods they brought into the state was unconstitutional. This case began when Daniel Webster argued in front of the court that such a tax violated Article I Section 10 of the Constitution which states "No State shall, without consent of Congress...lay any imposts or duties on imports or exports." The court agreed with Webster's argument and declared that since this particular tax did not have congressional approval it was therefore unconstitutional. This decision set an important precedent for future cases involving interstate commerce as it established limits to what states could do regarding taxation without federal permission.

In Brown and Others v. The State of Maryland, the Supreme Court was asked to decide whether a state could tax the Bank of the United States. Chief Justice Marshall delivered an opinion for a unanimous court that held that states do not have authority to impose taxes on federal institutions like the Bank of the United States. In his dissent, Justice Johnson argued that Congress had no power to create such an institution as it would be unconstitutional under Article I Section 8 Clause 4 which gives Congress exclusive powers over taxation and borrowing money from foreign nations or other states. He further argued that if Congress did have this power then they should also be able to regulate commerce with foreign nations and among several states, something which he believed was beyond their constitutional authority. Ultimately, however, Johnson's arguments were rejected by all nine justices in favor of Marshall's opinion holding that states cannot tax federal institutions like banks created by Congress without violating Article I Section 8 Clause 4