In the case of Humble Pipe Line Co. v. Waggonner, Sheriff in 1963, the U.S Supreme Court dealt with a dispute over taxation between an oil company and local authorities in Louisiana. The Humble Pipe Line Company argued that its pipelines should be classified as interstate commerce and thus exempt from state property taxes under federal law. However, local officials contended that since the pipelines were physically located within their jurisdiction, they could be taxed accordingly by them regardless of whether or not they facilitated interstate commerce. The court ruled in favor of the local authorities stating that while it was true that these pipes were used for transporting oil across state lines (interstate commerce), this did not make them immune to property tax at a state level because they are tangible properties permanently situated within Louisiana's borders. This decision clarified how physical infrastructure supporting interstate trade can still fall under certain aspects of state-level regulation and taxation despite being part of broader national economic activities.

In the dissenting opinion for Humble Pipe Line Co. v. Waggonner, Justice Black disagreed with the majority's decision to uphold Louisiana's ad valorem tax on oil stored temporarily in the state before being transported out of state. He argued that this ruling contradicted previous Supreme Court decisions which held that goods in transit through a state could not be subjected to taxation by that state, as it interfered with interstate commerce and violated the Commerce Clause of the Constitution. Justice Black expressed concern over potential negative impacts on national economic unity if states were allowed to impose taxes on transient commodities simply because they were within their borders for a short period of time.