In the case of Matthews et al. v. Rodgers et al., 1931, the U.S Supreme Court was tasked with determining whether a state law that imposed a tax on oil and gas produced within its borders violated the Commerce Clause of the Constitution by interfering with interstate commerce. The plaintiffs were oil companies who argued that since their product was destined for out-of-state markets, it should be exempt from taxation under Oklahoma's Gross Production Tax Law. However, the court ruled in favor of Rodgers and upheld Oklahoma's right to levy taxes on natural resources extracted within its boundaries before they enter into interstate commerce channels. The court reasoned that states have an inherent power to manage and control their own natural resources; therefore, taxing these resources does not interfere with or discriminate against interstate commerce.

In the dissenting opinion for Matthews et al. v. Rodgers et al., Justice Stone argued that the majority's decision to uphold a Mississippi tax on cotton futures contracts was inconsistent with previous Supreme Court rulings, which had struck down similar taxes as unconstitutional burdens on interstate commerce. He contended that this inconsistency undermined legal certainty and stability, making it difficult for businesses to predict how courts would interpret laws in future cases. Furthermore, he disagreed with the majority's view that cotton futures trading did not constitute interstate commerce because it involved only contractual rights rather than physical goods; instead, he believed such trading played an integral role in facilitating nationwide trade in actual commodities like cotton and thus should be protected from state interference under the Commerce Clause of the Constitution.