The Supreme Court case Looney, Attorney General of the State of Texas v. Crane Company in 1917 revolved around a dispute over taxation. The state of Texas attempted to impose an occupation tax on the Crane Company, which was incorporated in Illinois but had a warehouse and office in Texas where it conducted business. The company argued that this tax violated its rights under the Fourteenth Amendment's due process clause because it was not "doing business" within the traditional meaning as defined by law and thus should not be subject to such taxes. However, the court ruled against Crane Co., stating that having a warehouse and office for conducting transactions constituted doing business within legal definitions even if orders were filled out-of-state or goods were shipped from outside Texas directly to customers inside state borders.

In the dissenting opinion for Looney v. Crane Company, it was argued that the majority's decision to uphold a Texas law imposing an occupation tax on foreign corporations doing business in the state violated both due process and equal protection principles of the Fourteenth Amendment. The dissenting justices believed that this law unfairly discriminated against out-of-state businesses by subjecting them to additional taxation not imposed on domestic companies. They contended that such discrimination served no legitimate public purpose and thus constituted arbitrary and unreasonable state action. Furthermore, they asserted that this discriminatory treatment also infringed upon interstate commerce rights protected under federal law, thereby undermining national economic unity.