In the case of Platt, Treasurer of United States Express Company v. City of New York in 1913, the Supreme Court ruled on a dispute over taxation. The United States Express Company had been taxed by the city for its tangible property including horses and wagons used for transportation purposes. However, it was argued that these items were already being taxed under federal law and thus should be exempt from local taxes due to double taxation principles. The court disagreed with this argument stating that there is no constitutional principle preventing both state and federal governments from taxing the same item or entity as long as they are not identical taxes imposed for similar purposes by different authorities at exactly the same time period. Therefore, it upheld New York's right to impose its tax on top of any existing federal tax.

In the dissenting opinion for Platt v. City of New York, Justice Holmes disagreed with the majority's ruling that a tax imposed by New York on express companies was unconstitutional. He argued that it is not within the jurisdiction of federal courts to decide whether or not a state has exceeded its taxing power unless there is clear evidence of an infringement upon constitutional rights. In this case, he did not see any such violation and therefore believed that it should have been left up to local authorities to determine if they had overstepped their bounds in imposing taxes on interstate commerce businesses like United States Express Company. Furthermore, he pointed out inconsistencies in previous rulings regarding similar cases which further complicated matters and made him question the validity of this decision.