The case of Mid-Northern Oil Company v. J.W. Walker, et al., 1924 revolved around the issue of taxation on oil and gas leases in Montana. The plaintiff, Mid-Northern Oil Company, argued that a tax levied by the state was unconstitutional because it amounted to double taxation since they were already paying federal taxes on their income from these leases. However, the Supreme Court ruled against them stating that there was no constitutional prohibition against both federal and state governments taxing the same subject matter as long as it does not lead to an unfair or unreasonable burden upon interstate commerce or violate any other specific limitation imposed by constitution upon states' power to tax.

The dissenting opinion in the case of Mid-Northern Oil Company v. Walker et al., argued that the Montana state law imposing a tax on oil and gas production was unconstitutional. The justice disagreed with the majority's view that this taxation did not violate due process or equal protection rights under the Fourteenth Amendment, arguing instead that it unfairly targeted specific industries for revenue generation without providing them any special benefits or protections in return. They contended that such selective taxation amounted to an arbitrary exercise of power by the state government, which should be deemed unlawful under constitutional scrutiny. Furthermore, they expressed concern over potential negative impacts on economic development and investment incentives within these sectors if such discriminatory fiscal policies were allowed to stand unchallenged.