In the case of Northwest Airlines, Inc. v. Minnesota in 1943, the U.S Supreme Court ruled that states cannot tax airlines for planes that are not permanently located within their borders or predominantly conducting business there. The state of Minnesota had imposed a property tax on Northwest Airlines for its entire fleet of airplanes, despite many of them regularly flying interstate and international routes outside the state's jurisdiction. The court held this to be unconstitutional as it violated both Due Process Clause and Commerce Clause principles by unfairly taxing property beyond its reach and interfering with interstate commerce respectively. This ruling established an important precedent limiting how far states can extend their taxation powers over businesses operating across multiple jurisdictions.

The dissenting opinion in the case of Northwest Airlines, Inc. v. Minnesota argued that the state had a legitimate interest in regulating and taxing airlines operating within its borders, even if they were engaged in interstate commerce. The dissenting justices believed that the majority's decision undermined states' rights to regulate businesses for public welfare purposes and could lead to unfair competition among airlines. They also expressed concern about potential revenue loss for states due to this ruling, as well as possible negative impacts on local airports funded by these taxes. Furthermore, they disagreed with the majority's interpretation of federal law preempting state regulation in this area.