The U.S. Supreme Court case Itel Containers International Corporation v. Joe Huddleston, Commissioner of Revenue of Tennessee (1992) revolved around the issue of taxation on interstate commerce and whether it violated the Commerce Clause in the Constitution. The plaintiff, Itel Containers International Corporation, a company that leased cargo containers for use in international shipping, argued that Tennessee's tax on their business was discriminatory and thus unconstitutional as it imposed higher taxes on companies operating both within and outside state borders compared to those only operating within the state. However, the court ruled against Itel Containers stating that there was no discrimination because all businesses were subject to same tax rate regardless if they operated solely inside or also outside Tennessee’s borders. Furthermore, any differential treatment resulted from decisions made by businesses themselves rather than being imposed by law which did not violate principles established under Complete Auto Transit Inc., v Brady ruling regarding interstate commerce taxation.

In the dissenting opinion for ITEL Containers International Corporation v. Joe Huddleston, Commissioner of Revenue of Tennessee, Justice Scalia disagreed with the majority's interpretation of a federal statute that exempted certain containers from state taxation. He argued that the exemption should apply to all containers used in international shipping, not just those owned by foreign entities or their American agents as determined by the majority. According to him, this narrow interpretation was inconsistent with both Congress' intent and previous court decisions interpreting similar statutes. Furthermore, he contended that it unfairly discriminated against domestic companies like ITEL who were also engaged in international commerce but did not qualify for tax exemptions under this ruling.