In the 1932 case of New York v. Maclay et al., Receivers, et al., the Supreme Court dealt with a dispute over taxation between the state of New York and receivers for two railroad companies. The railroads had been taxed by both Pennsylvania and New York, but they argued that this constituted double taxation in violation of due process under the Fourteenth Amendment. The court ruled against them, finding that each state was within its rights to tax property located within its borders even if another state also claimed jurisdiction over it. This decision affirmed states' power to levy taxes on interstate commerce entities operating within their boundaries.

In the dissenting opinion for New York v. Maclay et al., Receivers, et al., Justice Stone argued that the Court's decision to uphold a Pennsylvania tax on freight transported from outside of the state was inconsistent with previous rulings and violated principles of interstate commerce. He contended that this ruling allowed states to impose taxes on goods simply because they were in transit through their territory, which he believed would lead to unfair taxation practices and hinder free trade between states. Furthermore, Justice Stone expressed concern about potential retaliation by other states imposing similar taxes, leading to an escalation of inter-state economic conflicts. He maintained that such issues should be addressed at a federal level rather than allowing individual states to set their own policies regarding interstate commerce.