The U.S. Supreme Court case Coffin Brothers & Company et al. v. Bennett, 1927, revolved around a dispute over land ownership in the state of California between the Coffin Brothers & Company and Mr. Bennett who claimed to have purchased it from an Indian woman named Maria Alviso under Spanish law before California became part of the United States in 1848. The court had to decide whether or not Maria Alviso was legally capable of selling her land according to Spanish laws at that time which stated that Indians could only sell their lands with government approval - something she did not obtain prior to selling her property. The Supreme Court ruled against Mr.Bennett stating that he failed to prove his claim as there were no records showing any grant by Spain or Mexico recognizing Maria's title nor evidence proving she obtained permission for sale from either government during their respective rules over California territory.

In the dissenting opinion for Coffin Brothers & Company et al. v. Bennett, it was argued that the majority's decision to uphold a California statute imposing an excise tax on corporations doing business within the state based on their total capital stock, regardless of whether some or all of that stock represented property located outside of California, violated both due process and equal protection clauses under the Fourteenth Amendment. The dissent contended that this taxation method unfairly burdened interstate commerce by taxing assets not within its jurisdiction and created inequality among businesses depending upon where their properties were situated. They believed this approach contradicted previous rulings which held states could only tax entities to an extent proportionate with what they owned or used within said state’s boundaries.