In the case of Hawkins v. Bleakly, Auditor of the State of Iowa et al., 1916, the U.S Supreme Court was tasked with determining whether a state law that required corporations to pay an annual tax based on their capital stock violated constitutional principles. The plaintiff, Mr. Hawkins, argued that this taxation system unfairly discriminated against out-of-state companies and thus contravened both due process and equal protection clauses in the Fourteenth Amendment as well as violating Article I's Commerce Clause which prohibits states from passing laws affecting interstate commerce. The court ruled in favor of Iowa’s auditor (Bleakly), upholding the constitutionality of such taxes for foreign corporations operating within its borders. They found no violation under either clause or article cited by Hawkins because it did not discriminate between domestic and foreign businesses but rather taxed all entities equally based on their capital stock value used or employed within Iowa.

In the dissenting opinion for Hawkins v. Bleakly, it was argued that the majority's decision to uphold Iowa's inheritance tax law as constitutional was incorrect. The dissenting justices believed that this law violated both due process and equal protection clauses of the Fourteenth Amendment because it unfairly taxed non-residents more heavily than residents on intangible personal property located within Iowa. They contended that a state does not have jurisdiction over such property simply because its owner dies while temporarily residing in another state, thus making any taxation of said property unconstitutional. Furthermore, they disagreed with the majority’s view that an individual’s domicile at death determines where their personal estate is located for tax purposes; instead arguing that location should be determined by where an asset has its situs or actual physical presence.