The U.S. Supreme Court case Department of Revenue of Oregon v. ACF Industries, Inc., et al., 1993 revolved around a dispute over the constitutionality of an Oregon tax law that exempted locally-owned property but taxed out-of-state companies for their use and ownership of intangible personal properties like leases or patents within the state. The plaintiffs, including ACF Industries and other railcar leasing companies who did not own property in Oregon, argued that this was discriminatory against interstate commerce and violated the Commerce Clause in the Constitution. However, the Supreme Court ruled unanimously in favor of Oregon's Department of Revenue stating that there is no requirement for states to provide identical taxation treatment to both local businesses and those engaged in interstate commerce as long as they are not discriminating against such commerce.

The dissenting opinion in the Department of Revenue of Oregon v. ACF Industries, Inc., et al., case argued that the majority's decision was inconsistent with previous rulings and principles established by the Court. The dissenters believed that Oregon's tax system did not violate constitutional requirements for uniformity because it treated all taxpayers equally - everyone had to pay a minimum tax regardless of their property holdings or income level. They also disagreed with the majority’s interpretation of “discrimination” under federal law, arguing that differential treatment is only discriminatory if it results in unequal burdens on different types of businesses. In this case, they saw no evidence that railroads were being unfairly burdened compared to other commercial and industrial taxpayers in Oregon.