In the case of Johnson, Treasurer of State of South Dakota v. Wells Fargo & Company in 1915, the Supreme Court ruled on a dispute over taxation between the state and a private corporation. The issue at hand was whether or not South Dakota could tax Wells Fargo for money held by its express business within the state's borders. The court found that while states have broad powers to levy taxes, they cannot do so in ways that interfere with interstate commerce - which is under federal jurisdiction according to Article I Section 8 Clause 3 (the Commerce Clause) of the U.S Constitution. Therefore, it was decided that South Dakota did not have authority to impose such a tax on Wells Fargo as it would be interfering with interstate commerce.

In the dissenting opinion for Johnson v. Wells Fargo & Company, it was argued that South Dakota's tax on foreign corporations should not be considered unconstitutional. The dissenting justices believed that the state had a right to impose such taxes as long as they were reasonable and did not discriminate against interstate commerce. They pointed out that the court majority’s decision could potentially undermine states' rights to regulate their own economies and protect local businesses from unfair competition by large, out-of-state corporations. Furthermore, they disagreed with the majority's interpretation of what constitutes "doing business" in a state, arguing that even minimal activities within a state can justify taxation under certain circumstances.