In the case of Coe v. Armour Fertilizer Works (1914), the United States Supreme Court ruled on a dispute involving property rights and damages caused by pollution. The plaintiff, Coe, owned land in Florida near a fertilizer plant operated by Armour Fertilizer Works. He alleged that emissions from the factory had damaged his orange groves and sued for compensation under Florida law which allowed recovery for physical damage to real or personal property resulting from another's negligence or unlawful act. The defendant argued that they were not liable because their operations were lawful and did not constitute an invasion of property rights as defined by common law principles. However, the court disagreed with this argument stating that even if an activity is legal, it does not exempt one from liability for harm caused to others' properties due to negligence or other wrongful acts. Therefore, despite operating within existing laws regarding its business practices, Armour Fertilizer Works was held accountable for any proven damages incurred upon Coe’s property as a result of its operation.

In the dissenting opinion for Coe v. Armour Fertilizer Works, it was argued that the majority's decision to allow a state law to regulate interstate commerce was in direct violation of the Commerce Clause of the U.S. Constitution. The dissenting justices believed that only Congress has this power and not individual states, as per their interpretation of federalism principles embedded within our constitutional framework. They contended that allowing Florida's Pure Food Law to apply in this case would set a dangerous precedent by permitting states to interfere with interstate trade and potentially disrupt national economic unity. Furthermore, they disagreed with how broadly 'commerce' had been defined by the majority ruling - extending beyond just buying and selling goods but also encompassing manufacturing processes - which they felt overstepped judicial boundaries into legislative territory.