In the 1919 case of Godchaux Company, Incorporated v. Estopinal, Sheriff of the Parish of St. Bernard et al., the U.S Supreme Court dealt with a dispute over property taxes. The Godchaux Company owned land in Louisiana that was assessed for taxation purposes at a value they believed to be excessive and discriminatory. They argued this violated their rights under both state law and the Fourteenth Amendment's Equal Protection Clause because other similar properties were not assessed at such high rates. However, when they sought relief from local courts, their claims were dismissed on procedural grounds without addressing these substantive issues. The Supreme Court held that it did not have jurisdiction to hear an appeal directly from a state court decision dismissing a suit on procedural grounds unless there is also some federal question involved in those procedures themselves or if there has been an authoritative construction by state courts denying federal rights claimed under color of Federal statute or Constitution.

The dissenting opinion in the case of Godchaux Company, Incorporated v. Estopinal argued that the majority's decision to uphold a Louisiana law requiring foreign corporations to pay taxes on debts owed by residents was unconstitutional. The dissent contended that this law violated both the Due Process and Equal Protection Clauses of the Fourteenth Amendment because it unfairly targeted out-of-state companies while exempting domestic ones from similar taxation. Furthermore, they believed that such a tax placed an undue burden on interstate commerce, thus infringing upon federal jurisdiction over such matters as established by Article I Section 8 Clause 3 of the Constitution (the Commerce Clause). They also pointed out inconsistencies with previous rulings where similar laws were struck down for these same reasons.