The Supreme Court case Commonwealth of Pennsylvania v. State of West Virginia in 1922 revolved around a dispute over the distribution and pricing of natural gas between states. The state of Pennsylvania sued West Virginia, alleging that it was being deprived its rightful share of natural gas due to laws passed by West Virginia which limited interstate commerce in favor of supplying local markets first. The court ruled in favor of Pennsylvania, stating that while individual states have control over their own resources, they cannot enact legislation that interferes with interstate commerce or discriminates against other states. This decision upheld the principle known as the Dormant Commerce Clause - an interpretation from Article I, Section 8, Clause 3 (the Commerce Clause) - which restricts state interference with interstate commerce even when Congress has not acted to regulate such activity.

In the dissenting opinion for the case Commonwealth of Pennsylvania v. State of West Virginia, Justice Holmes argued that there was no constitutional violation by West Virginia's actions to limit natural gas exports. He believed that states have a right to conserve their resources and protect public interests within their borders without interference from other states or federal government unless it directly contradicts federal law. Furthermore, he contended that interstate commerce should not be used as an excuse to prevent a state from exercising its rights over its own resources. In his view, if every state had unlimited access to another’s resources without any restrictions imposed by the resource-owning state itself, it would lead to chaos and exploitation of these resources with potential harm on local communities relying on them.