In the case of First Federal Savings & Loan Association of Boston et al. v. Tax Commission of Massachusetts et al., 1977, the U.S Supreme Court was tasked with determining whether a state tax on federal savings and loan associations violated the Supremacy Clause or Due Process Clause of the Constitution. The court held that it did not violate either clause, upholding Massachusetts' right to impose taxes on these institutions. The court reasoned that there was no discrimination against these entities as they were taxed similarly to other financial institutions in the state, thus not violating due process rights nor infringing upon federal supremacy by treating federally chartered entities differently from their counterparts at a state level.

In the dissenting opinion for First Federal Savings & Loan Association of Boston v. Tax Commission of Massachusetts, Justice William Rehnquist argued that the majority's decision to uphold a state tax on federal savings and loan associations was inconsistent with previous Supreme Court rulings. He contended that this ruling could potentially undermine the financial stability of these institutions by subjecting them to additional taxation from states in which they operate. Furthermore, he believed that such taxes were not necessary for states to maintain their fiscal health or provide public services, as other sources of revenue were available. Ultimately, Justice Rehnquist disagreed with the majority's interpretation of Congress' intent when it exempted federal savings and loan associations from certain types of state taxation.