The case Massachusetts v. United States, 1977 revolved around the issue of whether or not the federal government had to pay a state tax for its use of land within that state. The U.S. Supreme Court ruled in favor of the federal government, stating that it was exempt from paying such taxes under the Supremacy Clause of the Constitution which establishes that federal law takes precedence over state laws and regulations. In this case, Massachusetts attempted to impose a property tax on federally-owned land used by private parties for recreational purposes under lease agreements with Federal Government agencies. However, since these lands were owned by Federal Government entities and not private individuals or corporations, they were deemed immune from taxation by states according to constitutional principles.

In the dissenting opinion for Massachusetts v. United States, 1977, Justice William Rehnquist argued that the majority's decision to uphold federal regulations on state airports was an overreach of Congress' power under the Commerce Clause. He contended that while Congress has broad authority to regulate interstate commerce, it does not have unlimited power to impose its will on states in areas traditionally governed by state law such as local land use and zoning decisions related to airport construction and expansion. The justice believed this case represented a dangerous extension of federal authority into matters reserved for states under our system of dual sovereignty. Furthermore, he expressed concern about potential implications for other areas where both federal and state governments have legitimate interests like education or environmental protection if similar logic were applied.