In the case of Joy Oil Co., Ltd. v. State Tax Commission, 1948, the U.S Supreme Court examined whether a Michigan state tax on petroleum products violated the Commerce Clause of the Constitution by discriminating against interstate commerce. The tax in question was imposed on all petroleum products stored within Michigan for sale or use and did not distinguish between intrastate and interstate commerce. Joy Oil Company argued that this taxation scheme placed an undue burden on out-of-state businesses like theirs who imported oil into Michigan to be sold there. The court ruled in favor of the State Tax Commission, holding that while states cannot discriminate against interstate commerce through their taxation schemes, they are allowed to levy taxes that affect both intrastate and interstate business equally as long as these taxes do not create any direct commercial advantage for local businesses over those from out-of-state. This decision affirmed a state's right to impose non-discriminatory taxes affecting both intra- and inter-state trade under its police power without violating constitutional provisions protecting free trade among states.

In the dissenting opinion for Joy Oil Co., Ltd. v. State Tax Commission, it was argued that the majority's decision to uphold a Michigan tax on petroleum storage facilities unfairly targeted out-of-state businesses and violated principles of interstate commerce. The dissenting justices contended that this tax placed an undue burden on companies like Joy Oil, which stored their oil in Ohio but sold it in Michigan, as they were effectively being taxed twice: once by Ohio where their storage facilities were located and again by Michigan where their sales occurred. They believed this constituted discrimination against interstate commerce because local businesses storing and selling within Michigan only had to pay one such tax. Furthermore, they pointed out that there was no clear connection between the services provided by the state of Michigan and the imposed taxes since these companies did not use or benefit from any public utilities or services related to petroleum storage within its borders.