In the 1902 case of Diamond Match Company v. Ontonagon, the U.S Supreme Court ruled in favor of Diamond Match Company, overturning a decision by the Michigan Supreme Court. The dispute centered around whether or not a county could tax standing timber on land owned by non-residents but located within its jurisdiction. The court held that under Michigan law, standing timber was considered real property and thus subject to taxation by local authorities where it is situated regardless of ownership residency status. This ruling established an important precedent for how states can levy taxes on natural resources found within their borders.

In the dissenting opinion for Diamond Match Company v. Ontonagon, Justice Harlan argued that the majority's decision was inconsistent with previous rulings and principles of justice. He contended that a corporation should not be allowed to avoid paying taxes by claiming it had no taxable property in a state when its business operations were clearly benefiting from resources within that state. In this case, he believed the Diamond Match Company was using Michigan's timber resources for profit but avoiding taxation by claiming their property (the trees) weren't permanently situated there as they would eventually be cut down and removed. Harlan asserted this interpretation could lead to corporations exploiting states' natural resources without contributing financially through taxation, which he saw as fundamentally unfair and against public interest.