In the case of Gilbertville Trucking Co., Inc. v. United States, 1962, the Supreme Court ruled on a dispute involving interstate commerce and state taxation laws. The appellants were Massachusetts-based trucking companies that transported goods both within Massachusetts and across state lines into Connecticut and Rhode Island. They challenged an excise tax imposed by Massachusetts on their gross receipts from these interstate operations, arguing it violated the Commerce Clause of the U.S Constitution which prohibits states from interfering with interstate commerce. The Supreme Court rejected this argument, ruling in favor of the United States government and upholding the constitutionality of Massachusetts' tax law. It held that while states cannot impose taxes directly upon interstate commerce itself or discriminate against it in favor of local business activities, they can levy non-discriminatory taxes on businesses engaged in such trade as long as those taxes are fairly apportioned to reflect intrastate values and activities.

In the dissenting opinion for Gilbertville Trucking Co., Inc. v. United States et al., 1962, it was argued that the Interstate Commerce Commission (ICC) had exceeded its authority by imposing a requirement on carriers to file rate schedules for return trips when they were not charging anything extra for such service. The dissenters believed this constituted an unwarranted expansion of regulatory power over interstate commerce and violated principles of statutory interpretation as well as administrative law norms. They also contended that there was no evidence showing any harm or potential harm to shippers from non-filing of these rates, thus making ICC's action unnecessary and arbitrary in nature.