In the 1903 case of Public Clearing House v. Coyne, the US Supreme Court ruled on a matter concerning taxation and interstate commerce. The Public Clearing House in Chicago was an association that facilitated transactions between banks across state lines. It argued that it should not be subject to Illinois' tax laws because its activities constituted interstate commerce, which is under federal jurisdiction according to the Constitution's Commerce Clause. However, the court disagreed with this argument and upheld Illinois' right to impose taxes on such associations operating within its borders. The justices reasoned that while some aspects of banking could be considered as part of interstate commerce, they were also inherently local activities subject to state regulation and taxation.

The dissenting opinion in the case of Public Clearing House v. Coyne argued that the Illinois law, which required out-of-state corporations to have a certain amount of capital before they could do business within the state, was unconstitutional. The justice believed that this law violated both the Commerce Clause and Equal Protection Clause of the Constitution by unfairly discriminating against out-of-state businesses and restricting interstate commerce. They contended that states should not be allowed to impose such restrictions on companies simply because they are incorporated in another state, as it goes against principles of economic fairness and free trade among states.