In the Miller v. Ammon case of 1891, the U.S Supreme Court ruled on a dispute involving land ownership in Kansas. The plaintiff, Miller, claimed that he had purchased land from an individual who had acquired it through preemption rights under federal law. However, this was disputed by Ammon who argued that the original owner did not meet residency requirements to claim preemption rights and thus could not have legally sold the property to Miller. The court sided with Ammon's argument stating that for someone to qualify for preemption rights they must be either residing on or cultivating said lands at time of purchase which wasn't met in this case as per evidence provided. Therefore, any subsequent sale would also be invalid due to lack of valid initial ownership.

The dissenting opinion in the case of Miller v. Ammon argued that the majority's decision to uphold a Pennsylvania law taxing out-of-state corporations for doing business within its borders was unconstitutional. The dissenters believed this tax violated both the Commerce Clause and Equal Protection Clause of the Constitution, as it discriminated against interstate commerce by imposing an additional burden on out-of-state companies not faced by local businesses. They contended that such protectionist measures were contrary to free trade principles and could lead to economic retaliation from other states, thereby disrupting national unity and harmony. Furthermore, they asserted that there was no clear standard or definition for what constituted "doing business" in a state, leading to potential arbitrary enforcement of the law.