In the case of Ex parte Williams, Tax Commissioner in 1927, the U.S. Supreme Court dealt with a dispute over taxation and jurisdiction. The petitioner was a tax commissioner from West Virginia who sought to collect taxes on income derived from oil and gas wells located within Kentucky but owned by residents of West Virginia. The respondents were these owners who argued that they should not be taxed by both states for the same property. They claimed this constituted double taxation which violated their constitutional rights under the Fourteenth Amendment's Due Process Clause. The court ruled in favor of Williams, stating that each state has sovereign authority to tax all income its residents earn regardless if it is earned out-of-state or not unless there is an explicit agreement between states preventing such action. It held that while double taxation may seem unfair, it does not violate due process as long as each state exercises its power independently without encroaching upon another’s jurisdictional authority.

In the dissenting opinion for Ex parte Williams, Tax Commissioner, it was argued that the state of West Virginia had not violated any constitutional rights by imposing a tax on an out-of-state corporation. The dissenting justices believed that the state's power to levy taxes should be respected and upheld unless there is clear evidence of discrimination or violation of due process. They also disagreed with the majority's interpretation of interstate commerce laws, arguing that these laws do not exempt corporations from paying taxes in states where they conduct business activities. Furthermore, they contended that if every tax imposed on foreign corporations were considered as a burden on interstate commerce then no such corporation could ever be taxed by any State in which it does business; this would result in unfair advantages for foreign corporations over local businesses. Thus, according to them, upholding this taxation did not infringe upon federal authority but rather maintained balance between states' rights and federal powers.