In the case of Patapsco Guano Company v. North Carolina Board of Agriculture, 1897, the U.S Supreme Court ruled in favor of the state board's right to regulate commerce within its jurisdiction. The dispute arose when North Carolina enacted a law requiring all commercial fertilizers sold in the state to be inspected and analyzed by their Department of Agriculture for quality assurance purposes. This was met with resistance from out-of-state companies like Patapsco Guano who argued that this regulation violated both interstate commerce laws and their Fourteenth Amendment rights. However, Justice Edward D. White delivered an opinion stating that states have a legitimate interest in protecting consumers from fraud or harm caused by substandard products; thus they can impose reasonable regulations on businesses operating within their borders even if it affects interstate trade indirectly.

In the dissenting opinion for Patapsco Guano Company v. North Carolina Board of Agriculture, Justice Harlan argued that the majority's decision was a violation of interstate commerce regulations. He contended that the law in question, which imposed an inspection fee on commercial fertilizers sold within North Carolina regardless of their origin, unfairly burdened out-of-state manufacturers and sellers while favoring local ones. This, he believed, constituted discrimination against interstate commerce and thus violated the Commerce Clause of the U.S Constitution. Furthermore, Justice Harlan disagreed with the majority's view that this was a police power issue related to public health or safety; rather it was purely economic regulation aimed at protecting local industry from competition.