The U.S. Supreme Court case Connecticut General Life Insurance Co. v. Johnson, Treasurer of California in 1937 revolved around the issue of whether a state could tax an out-of-state corporation that did business within its borders without violating the Due Process Clause of the Fourteenth Amendment. The Connecticut General Life Insurance Company was incorporated in Connecticut but conducted business in California and other states as well. The State of California imposed a tax on foreign corporations for doing business within its jurisdiction, which the insurance company challenged as unconstitutional under the Fourteenth Amendment's Due Process Clause and Commerce Clause. In a 5-4 decision, Justice Benjamin Cardozo writing for majority upheld that such taxation by states does not violate either clause because it is based on benefits conferred upon them by state laws protecting their rights to do business there; hence they are obligated to pay taxes like any other resident businesses or individuals who enjoy those protections and services provided by local governments funded through taxation.

In the dissenting opinion for Connecticut General Life Insurance Co. v. Johnson, Justice Benjamin Cardozo argued that corporations should not be granted the same constitutional protections as individuals under the Fourteenth Amendment's Equal Protection Clause. He contended that a corporation is an artificial entity created by state law and thus does not possess inherent rights like natural persons do; instead, it only has those rights which are conferred upon it by its creating state or necessarily implied from such grant of powers. Therefore, he believed California had every right to tax out-of-state insurance companies differently than in-state ones without violating any constitutional principles because states have broad authority over their own internal affairs including taxation policy decisions related to business entities operating within their jurisdictional boundaries.