In the case of New Mexico v. United States Trust Company, 1898, the Supreme Court was asked to determine whether a tax imposed by the Territory of New Mexico on shares of national banks held by non-residents was constitutional. The U.S. Trust Company argued that this tax violated federal law which prohibited states from taxing national bank shares owned by non-residents at higher rates than those applied to other moneyed capital in the hands of residents. However, New Mexico contended that as a territory and not a state, it wasn't subject to these restrictions. The Supreme Court ruled in favor of U.S. Trust Company stating that while territories are not technically states under the Constitution, they must still adhere to federal laws unless specifically exempted - an exemption which did not exist for this particular statute concerning taxation on bank shares owned by non-residents. Therefore, despite its status as a territory rather than a state at that time (New Mexico didn’t become a state until 1912), it could not impose discriminatory taxes against out-of-territory shareholders without violating federal law.

The dissenting opinion in the case of New Mexico v. United States Trust Company argued that the Supreme Court should not have jurisdiction over this matter, as it was essentially a dispute between two states - New Mexico and Colorado. The justice believed that such disputes should be resolved by Congress rather than the courts, citing Article III of the Constitution which grants original jurisdiction to interstate controversies to Congress. Furthermore, they disagreed with majority's interpretation of "public lands," arguing that these were indeed state lands and thus outside federal purview. They also expressed concern about potential implications for other western states where large tracts of public land exist if federal government could intervene in their management or disposal without explicit congressional authorization.