In the 1939 case of Pittman, Clerk of the Superior Court of Baltimore v. Home Owners' Loan Corp., the U.S Supreme Court ruled in favor of Home Owners' Loan Corporation (HOLC), a federal agency created during the Great Depression to help homeowners refinance their mortgages and avoid foreclosure. The issue at hand was whether or not HOLC was exempt from paying recording fees for deeds and other documents under Maryland state law due to its status as a federal entity. The court held that since HOLC was an instrumentality of the United States government, it could not be subjected to state taxation without express congressional authorization, which did not exist in this instance. Therefore, it concluded that HOLC was indeed exempt from such charges imposed by states like Maryland.

In the dissenting opinion for Pittman v. Home Owners' Loan Corp., Justice McReynolds argued that the majority's decision was a departure from established principles of federalism and state sovereignty. He contended that Maryland had every right to tax federal corporations operating within its borders, as long as it did so in a non-discriminatory manner. The justice believed that this case represented an unwarranted expansion of immunity for federally chartered corporations from state taxation, which could lead to serious consequences for states' abilities to raise revenue and regulate commerce within their jurisdictions. Furthermore, he disagreed with the majority's interpretation of Congress's intent when creating the Home Owners' Loan Corporation (HOLC), arguing there was no clear indication they intended to exempt HOLC from all forms of state taxation.