In the case of The Corn Exchange Bank v. Coler, Commissioner of Public Welfare in 1929, the United States Supreme Court ruled on a dispute involving property rights and tax law. The Corn Exchange Bank had purchased bonds from New York City which were later deemed to be illegally issued by the city due to exceeding its constitutional debt limit. When these bonds defaulted, the bank sought reimbursement for their losses from Bird S. Coler, who was then serving as Commissioner of Public Welfare for New York City. The court held that although it was illegal for New York City to issue such bonds under state law, this did not invalidate them entirely or absolve purchasers like The Corn Exchange Bank from risk associated with buying them; rather they remained valid obligations between buyer and seller but could not be enforced against third parties (like taxpayers). Therefore, even though these transactions were unlawful according to state constitution provisions limiting municipal indebtedness levels - an illegality known at time purchase - there still existed a contractual relationship obligating issuer (New York) towards bondholder (Corn Exchange), despite inability enforce said obligation through normal legal channels because doing so would violate public policy considerations protecting taxpayer interests.

In the dissenting opinion for The Corn Exchange Bank v. Coler, Commissioner of Public Welfare case in 1929, it was argued that the majority's decision to uphold a New York law allowing banks to be taxed on shares held by non-residents violated both the Due Process and Commerce Clauses of the Constitution. The dissent contended that this taxation unfairly burdened interstate commerce as it imposed taxes on out-of-state shareholders based solely on their ownership of stock in a New York bank. Furthermore, they believed this tax violated due process rights because these non-resident shareholders had no voice or representation in how these funds were used within New York State. They also pointed out inconsistencies with previous rulings where similar laws were struck down as unconstitutional. Therefore, they disagreed with upholding such an unjust law.