In the 1952 case of Esso Standard Oil Co. v. Evans, Commissioner of Finance and Taxation, et al., the U.S Supreme Court ruled in favor of Esso Standard Oil Company (now ExxonMobil). The issue at hand was whether or not Alabama's Privilege Tax law violated the Commerce Clause by taxing interstate commerce activities unfairly. The tax imposed a levy on companies for storing oil within state borders before it was transported out-of-state. Esso argued that this constituted an unfair burden on interstate commerce as it taxed goods destined for other states while exempting those sold within Alabama from taxation. The court agreed with Esso’s argument and held that such a tax indeed placed an undue burden on interstate commerce, thereby violating the Commerce Clause of the Constitution which grants Congress exclusive power to regulate trade between states. This decision reinforced principles established in previous cases regarding discriminatory state taxation practices against interstate businesses.

The dissenting opinion in the case of Esso Standard Oil Co. v. Evans, Commissioner of Finance and Taxation, et al., argued that the majority's ruling was inconsistent with previous decisions made by the Supreme Court regarding interstate commerce and taxation. The dissenters believed that Alabama's tax on gasoline stored temporarily within its borders before being shipped out-of-state constituted an unconstitutional burden on interstate commerce. They contended that this storage was a necessary incident to transportation and thus should be considered part of the flow of interstate commerce, making it immune from state taxation under established precedents like Carson Petroleum Co. v. Vial (1935). Furthermore, they disagreed with the majority’s view that Esso had not proven enough about how often or regularly these temporary stoppages occurred to demonstrate their necessity for transportation; instead, they felt such details were irrelevant as long as these stoppages were indeed part of regular business operations.