In the case of Ohio v. Thomas in 1898, the U.S. Supreme Court ruled on a dispute involving taxation and interstate commerce. The defendant, Thomas, was an agent for several non-Ohio insurance companies who conducted business within Ohio but did not have physical offices there. The state of Ohio sought to tax these out-of-state businesses under its foreign insurance company law which imposed taxes on premiums collected by such companies from policies issued in Ohio. Thomas argued that this violated the Commerce Clause of the Constitution as it amounted to a direct tax on interstate commerce activities - something only Congress could do according to his interpretation. The Supreme Court disagreed with Thomas's argument and upheld Ohio's right to impose such taxes stating that they were not directly taxing interstate commerce but rather imposing a privilege tax for conducting business within their jurisdiction. This decision affirmed states' rights to levy taxes against out-of-state corporations operating within their borders without violating constitutional protections around interstate trade.

In the dissenting opinion for Ohio v. Thomas, 1898, it was argued that the majority's decision to uphold a tax on commercial brokers violated both state and federal constitutions. The dissenting justices believed that this tax constituted an unlawful interference with interstate commerce because it imposed a burden on out-of-state businesses not faced by in-state companies. They also contended that the law was discriminatory as it exempted certain types of brokers from taxation while imposing taxes on others without any rational basis for such distinction. Furthermore, they disagreed with the majority's interpretation of what constitutes "doing business" within a state, arguing instead that merely soliciting orders does not constitute doing business and should therefore not be subject to taxation under state law.