In the 1901 case of League v. Texas, the U.S Supreme Court dealt with a dispute over land ownership in Texas. The plaintiff, League, claimed that he had purchased a tract of land from an individual who had received it as part of a Spanish grant before Mexico's independence and subsequently before Texas became part of the United States. However, this claim was disputed by the state on grounds that there were no records to prove such transaction or grant existed prior to its annexation into US territory. The court ruled in favor of Texas stating that under international law and treaties between Spain, Mexico and the United States; any grants made after certain dates would not be recognized unless they were properly recorded at time when these territories changed hands. Since there was no record for this particular piece of property being granted or sold during those periods specified within respective treaties; it remained public domain under control by State government rather than private property owned by Mr.League.

In the dissenting opinion for League v. Texas, Justice John Marshall Harlan argued that the majority's decision was inconsistent with previous rulings of the court and violated principles of federalism. He contended that states should not have unlimited power to regulate interstate commerce, as this could lead to protectionist policies and conflicts between states. Furthermore, he believed that Congress had exclusive authority over interstate commerce under the Commerce Clause of the Constitution. Therefore, in his view, a state law prohibiting an out-of-state corporation from doing business within its borders without obtaining a license was unconstitutional because it interfered with interstate commerce. He also disagreed with the majority's interpretation of what constituted "doing business," arguing that occasional or incidental transactions did not amount to conducting regular operations within a state.