In the case of Mullaney, Commissioner of Taxation of the Territory of Alaska v. Anderson et al., 1951, the Supreme Court ruled on a dispute over taxation in Alaska. The court held that an Alaskan tax law which imposed higher taxes on non-residents than residents was unconstitutional as it violated both due process and equal protection clauses under the Fourteenth Amendment. This decision came after Anderson and others challenged their tax assessments arguing they were unfairly targeted because they weren't permanent residents but still owned property in Alaska. The state argued that this differential treatment was justified by additional administrative costs associated with taxing non-residents' properties; however, this argument failed to convince the court which found no reasonable basis for such discrimination.

In the dissenting opinion for Mullaney v. Anderson, Justice Frankfurter argued that Alaska's tax laws should be upheld and enforced as they were written. He believed that it was not within the Supreme Court's jurisdiction to question or reinterpret these laws based on their potential impact on non-residents of Alaska. According to him, if there was an issue with how these taxes affected non-residents, it should have been addressed by Congress rather than the courts. Furthermore, he disagreed with the majority’s view that this taxation violated due process rights under Fourteenth Amendment because he did not see any discriminatory treatment between residents and nonresidents in terms of procedural safeguards provided by Alaskan law before imposing a tax liability.