In Fullerton v. Texas, 1904, the U.S. Supreme Court addressed a dispute over land ownership in El Paso County, Texas. The plaintiff, Fullerton, claimed that he had purchased the disputed property from its original owner and was therefore entitled to it under federal law. However, the defendant argued that they had acquired title to the property through adverse possession - a legal doctrine allowing someone who has occupied or used another's property for an extended period of time without challenge from the rightful owner to claim ownership of it themselves. The Supreme Court ruled against Fullerton on two grounds: firstly because his purchase did not meet certain requirements set out by Congress for such transactions; secondly because even if his purchase had been valid under federal law, state laws regarding adverse possession would still apply and override his claim. This case is significant as it established precedent concerning how conflicts between state and federal laws are resolved when dealing with issues related to real estate transactions and land rights.

In the dissenting opinion for Fullerton v. Texas, it was argued that the majority's decision to uphold a tax on interstate commerce conflicted with previous rulings of the court and violated constitutional principles. The dissent contended that by taxing an agent who sold goods shipped from another state, Texas effectively imposed a burden on interstate commerce which is prohibited under the Commerce Clause of the Constitution. It was further pointed out that this case differed significantly from others where taxes were upheld because in those instances, there was always some form of intrastate activity or property involved whereas here, all activities related to selling took place outside Texas' jurisdiction. Therefore, according to this view, such taxation should be deemed unconstitutional as it interferes with free trade among states and infringes upon federal authority over interstate commerce.