In the case of General Motors Corp. v. Washington, the Supreme Court ruled in favor of Washington state, upholding its right to tax out-of-state corporations for business activities conducted within its borders. The court found that General Motors Corporation's operations in Washington were sufficient enough to establish a taxable nexus under both Due Process and Commerce Clauses of the Constitution. This decision was significant as it clarified how states could levy taxes on interstate commerce without violating constitutional principles or federal law.

In the dissenting opinion for General Motors Corp. v. Washington, it was argued that the majority's decision to uphold Washington state's business and occupation tax on car manufacturers violated the Commerce Clause of the U.S. Constitution by discriminating against interstate commerce. The dissenters believed that this tax unfairly burdened out-of-state businesses like General Motors because they were taxed at a higher rate than in-state businesses conducting similar activities, even though their cars were not sold directly to consumers within Washington but rather through independent dealerships who paid their own taxes on these sales transactions. They also contended that this case should have been decided based on its specific facts rather than being treated as a broad constitutional issue about states' rights to levy taxes on interstate commerce.