In the case of Massachusetts v. White in 1978, the state of Massachusetts sued Francis X. White, a federal employee who was also a resident of Massachusetts, for unpaid income taxes. The Supreme Court ruled that states cannot tax the salaries of federal employees unless they also tax state and local government workers' salaries at an equal rate. This decision was based on intergovernmental immunity doctrine which prevents one level of government from interfering with operations at another level by imposing taxes or regulations on its activities or property. In this case, it meant that because Massachusetts did not tax its own employees’ wages but sought to do so for federal employees', it violated this principle and thus could not collect those taxes from Mr.White.

In the dissenting opinion for Massachusetts v. White, the justice argued that the majority's decision was a departure from established precedent and an intrusion into states' rights. The justice contended that previous cases had set a clear standard: federal courts should not interfere in state tax matters unless there is clear and manifest violation of constitutional rights. In this case, he believed no such violation existed; instead, it was simply a matter of policy disagreement between Massachusetts and its taxpayers about how to distribute tax burdens among different types of property owners. He also expressed concern over potential consequences of this ruling on future disputes involving state taxation policies or practices, fearing it could open floodgates to litigation challenging these decisions based on subjective notions of fairness rather than objective legal standards.