In the case of Doud et al., Doing Business as Bondified Systems, et al. v. Hodge, Auditor of Public Accounts of Illinois, et al., 1955, the U.S Supreme Court ruled that a state could not tax out-of-state businesses for services performed within its borders if those services were part and parcel to interstate commerce. The plaintiffs in this case were an Ohio-based company who provided credit reporting and collection services to clients across multiple states including Illinois. They argued that they should not be subject to taxation by the State of Illinois because their business constituted interstate commerce which was protected from state taxation under the Commerce Clause of the U.S Constitution. The court agreed with them ruling that while states have broad powers to levy taxes on businesses operating within their borders; these powers do not extend to taxing activities which are fundamentally related to interstate commerce.

The dissenting opinion in the case of Doud et al., Doing Business As Bondified Systems, et al. v. Hodge, Auditor of Public Accounts Of Illinois, et al., argued that the majority's decision was inconsistent with previous rulings and principles regarding interstate commerce regulation. The dissenters believed that by allowing a state to regulate an aspect of interstate commerce - specifically, insurance sales - it would set a dangerous precedent for other states to do so as well. They contended this could lead to burdensome regulations on businesses operating across state lines and potentially disrupt national economic unity. Furthermore, they disagreed with the majority's interpretation of Congress' intent when passing relevant legislation; they felt Congress intended for federal law to supersede any conflicting state laws related to interstate commerce.