In the case of Minnesota v. Brundage in 1900, the U.S Supreme Court ruled on a dispute involving taxation and interstate commerce. The state of Minnesota had imposed taxes on grain elevators owned by non-residents, including Mr. Brundage from Illinois who argued that this was an unconstitutional interference with interstate commerce. However, the court upheld Minnesota's right to tax these properties as they were physically located within its jurisdiction and provided services for profit there. The justices reasoned that while states cannot impose levies directly affecting interstate trade (such as tariffs), they can tax property or businesses operating within their borders even if those entities are involved in such trade indirectly.

The dissenting opinion in the case of Minnesota v. Brundage argued that the state had no right to tax railroad companies for land grants given by Congress, as it would interfere with federal authority and violate the Constitution's Supremacy Clause. The justice contended that these lands were granted under a contract between Congress and the railroads, which should be respected by states. He also disagreed with majority’s interpretation of previous court decisions on similar issues, arguing they did not establish a precedent for taxing such lands but rather upheld contracts made under federal law from state interference. Furthermore, he believed this taxation could discourage future private-public partnerships if businesses feared their agreements might be undermined by unexpected taxes imposed later by states.