In the case of Perley et al. v. State of North Carolina (1918), the plaintiffs, who were shareholders in a corporation, sued to challenge an amendment to North Carolina's constitution that imposed income tax on dividends received from corporations doing business within the state. The plaintiffs argued that this was a violation of their rights under both federal and state constitutions as it resulted in double taxation - once when corporate profits were taxed and again when these profits were distributed as dividends to shareholders. However, the U.S Supreme Court upheld North Carolina’s right to impose such taxes stating that there is no constitutional prohibition against double taxation and dismissed all other claims by the plaintiffs for lack of jurisdiction.

The dissenting opinion in the case of Perley et al. v. State of North Carolina argued that the majority's decision to uphold a state law restricting out-of-state corporations from doing business within its borders was unconstitutional and violated principles of interstate commerce. The dissenting justices contended that such laws unfairly discriminated against non-resident businesses, thereby infringing upon their rights under the Fourteenth Amendment’s Equal Protection Clause. They also expressed concern over potential negative impacts on national economic unity and free trade among states, warning that allowing individual states to enact protectionist policies could lead to economic fragmentation and inefficiency across the country.