In the case of Hazelton v. Sheckells in 1905, the United States Supreme Court ruled on a dispute regarding land ownership and mining rights in Nevada. The plaintiff, Hazelton, claimed that he had purchased mining property from an individual who had obtained it through a sheriff's sale after winning a judgment against its previous owner. However, the defendant, Sheckells argued that this was not valid as there were procedural errors during the sheriff's sale which made it invalid under Nevada law. The court sided with Sheckells and held that since proper procedures were not followed during the sheriff’s sale (including failure to provide public notice), title did not pass to Hazelton when he bought it from his predecessor-in-interest who acquired it at said flawed auction.

In the dissenting opinion for Hazelton v. Sheckells, it was argued that the majority's decision to uphold a Maryland law taxing out-of-state corporations doing business within its borders violated both the Due Process and Equal Protection Clauses of the Fourteenth Amendment. The dissenting justices believed that this tax placed an unfair burden on interstate commerce and discriminated against non-Maryland businesses by treating them differently from in-state companies. They contended that such discrimination could potentially lead to economic retaliation from other states, thereby disrupting national unity and harmony among states. Furthermore, they asserted that while states have broad powers to levy taxes, these powers should not be used as a means of protectionism or favoritism towards local industries at the expense of out-of-state competitors.