In the 1990 case Ford Motor Credit Company, Inc. v. Department of Revenue, State of Florida, the U.S Supreme Court ruled in favor of Ford Motor Credit Company (FMCC). The dispute arose when FMCC was taxed by Florida on interest from finance contracts sold to out-of-state dealerships. The court held that this taxation violated the Due Process Clause and Commerce Clause as it applied to interstate commerce activities which were not sufficiently connected with Florida for tax purposes. This decision clarified that a state cannot tax an entity unless there is a substantial nexus between its economic activity and the taxing state.

In the dissenting opinion for Ford Motor Credit Company, Inc. v. Department of Revenue, State of Florida (1990), it was argued that the majority's decision to uphold Florida's tax scheme violated principles of interstate commerce and fair apportionment. The dissenters believed that by taxing only a portion of Ford’s income derived from its financing activities in Florida, while also taxing all income from sales within the state regardless if financed by Ford or not, resulted in double taxation and unfairly burdened interstate businesses like Ford. They contended this approach failed to meet constitutional requirements for fairness as it did not accurately reflect how much business activity actually occurred within the state boundaries compared to elsewhere.