In the case of Cheney Brothers Company et al. v. Commonwealth of Massachusetts, 1917, the U.S Supreme Court was tasked with determining whether a Massachusetts law that prohibited corporations from deducting fines imposed on them for violating labor laws from their taxable income violated the Due Process Clause of the Fourteenth Amendment. The Cheney Brothers Company had been fined for violating state labor laws and sought to deduct these fines when calculating its corporate excise tax liability in Massachusetts. The company argued that this prohibition constituted an arbitrary deprivation of property without due process of law because it effectively increased their punishment beyond what was prescribed by statute for violation of labor laws. The court ruled against Cheney Brothers Company, upholding the constitutionality of the Massachusetts law prohibiting such deductions. It held that there was no constitutional right to a deduction and therefore no deprivation occurred as a result thereof; thus, there could be no violation under Due Process Clause.

The dissenting opinion in the Cheney Brothers Company v. Commonwealth of Massachusetts case argued that the state law, which required foreign corporations to obtain a license before doing business within its borders and pay an annual fee based on capital stock, was unconstitutional. The justice believed it violated both the Commerce Clause and Equal Protection Clause of the U.S Constitution. He contended that this law placed an undue burden on interstate commerce by imposing additional costs solely on out-of-state companies while exempting domestic ones from such fees. Furthermore, he asserted that it discriminated against foreign corporations without any rational basis for differentiation, thereby infringing upon their equal protection rights under Fourteenth Amendment.