The U.S. Supreme Court case Michelin Tire Corp. v. Wages, Tax Commissioner, et al., 1975 revolved around the issue of whether a state could impose a tax on imported goods stored in an importer's warehouse prior to their distribution and sale within the United States without violating the Import-Export Clause of the Constitution. The court ruled in favor of Michelin Tire Corporation stating that such taxes were not unconstitutional as long as they did not interfere with federal power over foreign commerce or discriminate against imports when compared to domestic products. This decision overturned Low v Austin (1872) which had previously held that states could not tax imported goods until they had been "broken up" from their original packages for use or resale.

In the dissenting opinion for Michelin Tire Corp. v. Wages, Justice William O. Douglas argued that the majority's decision to uphold a Georgia tax on imported tires was inconsistent with previous rulings and violated the Import-Export Clause of the U.S Constitution. He contended that this clause prohibits states from imposing taxes on imports or exports without congressional consent, regardless of whether they are in their original package or not when sold by an importer within state lines. In his view, allowing such taxation would undermine national uniformity in dealing with foreign trade and could potentially lead to international discord if individual states were permitted to impose discriminatory taxes against goods from certain countries.