In the case of Heider, Administrator v. Michigan Sugar Co., 1966, the Supreme Court was asked to decide on a dispute over inheritance tax laws in Michigan. The administrator of an estate argued that certain shares in a sugar company should not be included in the gross estate for taxation purposes because they were owned by non-residents at the time of death. However, under Michigan law, all property located within state borders is subject to its inheritance tax regardless of where its owners reside. The court ruled against Heider and upheld this aspect of Michigan's inheritance tax law as constitutional under both federal and state constitutions.

The dissenting opinion in the case of Heider, Administrator v. Michigan Sugar Co., 1966 argued that the majority's decision to uphold a state law requiring sugar beet growers to sell their crops only to processors within the state was unconstitutional. The dissenters believed this violated both the Commerce Clause and Equal Protection Clause of the Constitution. They contended that such laws unfairly restricted interstate commerce by preventing out-of-state processors from buying Michigan-grown beets, thereby creating an unjustifiable trade barrier between states. Furthermore, they asserted that these restrictions also violated equal protection rights by discriminating against non-Michigan residents who wished to engage in lawful commercial activities within its borders but were prevented from doing so due solely on their residency status.