In the 1933 case Federal Compress & Warehouse Co. et al. v. McLean, Sheriff, et al., the U.S Supreme Court ruled on a dispute involving tax assessment and collection in Mississippi. The plaintiffs were out-of-state corporations operating cotton compresses within Mississippi but claimed they were being unfairly taxed by local authorities who assessed their property at full value while other properties were undervalued for tax purposes - an alleged violation of the Equal Protection Clause of the Fourteenth Amendment to the Constitution which guarantees equal protection under law to all citizens regardless of state or territory. The court held that if there was systematic and intentional discrimination against these companies then it would be unconstitutional; however, mere errors or mistakes in assessments did not constitute such discrimination. Furthermore, it was noted that taxpayers must seek remedy through state channels before appealing to federal courts unless those remedies are inadequate or unavailable. Ultimately, this case affirmed states' rights to manage their own taxation systems with minimal interference from federal courts as long as no deliberate discriminatory practices could be proven.

In the dissenting opinion for Federal Compress & Warehouse Co. et al. v. McLean, Sheriff, et al., Justice Brandeis argued that the majority's decision was a departure from established principles of federalism and comity between state and federal courts. He contended that there was no constitutional barrier preventing Mississippi from imposing its tax on cotton stored in federally bonded warehouses within its borders because it did not interfere with any function of the federal government or violate any right granted by Congress to these companies under their bonds. The justice believed that this case should have been decided based on whether or not the tax imposed an undue burden on interstate commerce rather than being dismissed outright as violating supremacy clause principles without proper consideration.