In the case of Cockrill et al. v. People of California, 1924, the U.S Supreme Court upheld a decision by the State of California to impose taxes on property owned by non-residents in its jurisdiction. The plaintiffs were residents and taxpayers from other states who owned properties in California but objected to paying additional taxes imposed on their properties due to their non-resident status. They argued that this was discriminatory and violated both the Due Process Clause and Equal Protection Clause under Fourteenth Amendment rights as well as Article I, Section 8 (the Commerce clause) of the Constitution which prohibits any state from imposing tax burdens on out-of-state entities or individuals unfairly. However, after reviewing these claims, Justice Oliver Wendell Holmes Jr., writing for a unanimous court ruled against them stating that there was no violation because taxation is inherently local matter within each state's power so long it does not discriminate between similarly situated resident and nonresident owners.

The dissenting opinion in the case of Cockrill et al. v. People of California argued that the majority's decision to uphold a state law prohibiting non-residents from fishing in state waters was unconstitutional. The dissenters believed this law violated the Privileges and Immunities Clause, which prevents states from discriminating against citizens of other states without justification. They contended that there was no substantial reason for California to discriminate against out-of-state fishermen because they did not pose any unique threat to fish populations compared with resident fishermen. Furthermore, they argued that such discrimination could lead to retaliatory measures by other states, thereby undermining national unity and cooperation among states.