In the 1892 case of Luxton v. North River Bridge Company, the U.S. Supreme Court ruled in favor of the North River Bridge Company, upholding its right to charge tolls for use of a bridge it had built across the Hudson River between New York and New Jersey. The plaintiff, Luxton, argued that this violated his constitutional rights under Article I Section 10 which prohibits states from imposing duties on imports or exports without Congress's consent. However, the court held that these provisions did not apply as they were intended to prevent states from levying taxes on foreign commerce or interstate trade; whereas here it was merely a fee for using a private facility - akin to paying rent - rather than an impost upon goods transported across state lines per se. Furthermore, since Congress had authorized construction of said bridge with power to exact reasonable compensation for its use via tolls (Act Feb 16th 1886), there was no conflict with federal law either.

In the dissenting opinion for Luxton v. North River Bridge Company, it was argued that the Supreme Court lacked jurisdiction over this case because there was no controversy between parties from different states. The argument stated that both plaintiff and defendant were citizens of New York, thus making it a local dispute rather than an interstate one. Furthermore, they contended that even though Congress had authorized construction of the bridge in question under its power to regulate commerce among several states, this did not automatically make all disputes related to said bridge federal matters. They believed such interpretation would unduly expand federal jurisdiction into areas traditionally reserved for state courts and could potentially infringe upon state sovereignty rights protected by Constitution's Tenth Amendment.