In Huddleston et al. v. Dwyer et al., the U.S Supreme Court was tasked with deciding whether a state could tax income earned by an out-of-state corporation from its operations within the state, even if that income was not directly derived from property or business in the state. The case involved two corporations incorporated in Delaware and Pennsylvania respectively but operating coal mines in West Virginia. The State of West Virginia imposed a tax on their net incomes which included profits made from selling coal outside of West Virginia. The corporations argued this violated their rights under both the Due Process Clause and Commerce Clause of the Constitution, as they were being taxed for activities conducted entirely outside of West Virginia's jurisdiction. However, the Supreme Court ruled against them stating that since these companies had availed themselves to benefits provided by West Virginian law such as protection for their mining operations and access to local courts among others, it was only fair they pay taxes on all income earned through those protected activities regardless where sales occurred.

In the dissenting opinion for Huddleston et al. v. Dwyer et al., Justice Frank Murphy argued that the majority's decision to uphold a Tennessee law requiring voters to pay poll taxes violated the Fourteenth Amendment of the U.S Constitution, which guarantees equal protection under law. He contended that such laws were designed to disenfranchise poor and minority voters, thereby undermining democratic principles of universal suffrage and equality. Furthermore, he believed this ruling contradicted previous Supreme Court decisions that had struck down similar discriminatory practices in other states. Thus, he disagreed with his colleagues' interpretation of constitutional rights and protections in relation to voting access.