In the case of Citizens' Telephone Company of Grand Rapids v. Fuller, Auditor-General of the State of Michigan, 1912, the Supreme Court was asked to determine whether a state law that imposed a specific tax on telephone companies violated constitutional protections against unequal taxation. The plaintiff argued that this tax unfairly targeted their business and constituted an illegal taking without due process or equal protection under the Fourteenth Amendment. However, the court ruled in favor of Michigan's auditor-general and upheld the constitutionality of such taxes. The justices reasoned that states have broad powers to levy taxes as they see fit unless there is clear evidence showing discrimination or violation against any particular class protected by federal laws.

In the dissenting opinion for Citizens' Telephone Company of Grand Rapids v. Fuller, it was argued that the Michigan law imposing a specific tax on telephone companies violated both state and federal constitutions. The justice believed that this tax was not fairly apportioned among all businesses in the state, but instead unfairly targeted telephone companies. He also contended that this taxation method infringed upon interstate commerce by taxing out-of-state calls made through these companies, which he saw as an overreach of state power into federal jurisdiction. Furthermore, he disagreed with the majority's interpretation of previous case law regarding similar issues and felt they had misapplied those precedents to reach their decision.