In the case of Old Dominion Steamship Company v. Virginia, 1904, the U.S. Supreme Court ruled that a state could not impose taxes on interstate commerce activities beyond its jurisdictional boundaries. The Old Dominion Steamship Company was an interstate business with operations in several states including New York and Virginia. The company's headquarters were located in New York but it also had offices and wharves in Norfolk, Virginia where it loaded and unloaded cargo from ships traveling between various ports along the Atlantic coast. The State of Virginia imposed a tax on all gross receipts earned by companies operating within its borders which included revenue generated outside of the state as well as income derived from interstate commerce activities such as shipping freight across state lines. This led to double taxation for businesses like Old Dominion who were already paying taxes on these earnings in other states. The court held that this practice violated both due process rights under Fourteenth Amendment and Commerce Clause protections against discriminatory or burdensome taxation by individual states on interstate trade or commerce.

The dissenting opinion in the case of Old Dominion Steamship Company v. Virginia argued that the state had a right to tax property within its jurisdiction, regardless of whether it was used for interstate commerce or not. The justice disagreed with the majority's interpretation of constitutional law and believed that there should be no exception for vessels engaged in interstate trade. He contended that such an exemption would unfairly burden other forms of property and disrupt states' abilities to raise revenue through taxation. Furthermore, he asserted that this decision contradicted previous rulings by the court which upheld similar taxes on railroad cars involved in interstate commerce. Ultimately, he maintained that if a vessel is physically present within a state and benefits from its laws and protections, then it should be subject to taxation like any other piece of property.