In the case of Puget Sound Stevedoring Co. v. State Tax Commission, the Supreme Court examined whether a Washington state tax on stevedoring companies violated the Commerce Clause of the U.S. Constitution by interfering with interstate commerce. The tax in question was levied on gross income from loading and unloading cargo ships, which often involved goods moving between states or countries. The petitioner argued that this activity constituted interstate commerce and thus could not be taxed by individual states under federal law. The court ruled against Puget Sound Stevedoring Co., upholding Washington's right to impose such taxes as long as they did not discriminate against out-of-state entities or create undue burdens on interstate commerce. It found that while stevedoring activities were part of broader commercial processes crossing state lines, these specific services occurred entirely within Washington's jurisdiction and therefore could be subject to local taxation without violating federal law.

In the dissenting opinion for Puget Sound Stevedoring Co. v. State Tax Commission, it was argued that the tax imposed by Washington state on stevedoring companies did not violate the Commerce Clause of the U.S. Constitution as claimed by the majority ruling. The dissenting justices believed that this tax should be viewed as a general business privilege tax rather than an unconstitutional burden on interstate commerce because it applied to all businesses in Washington, regardless of whether they were involved in interstate or intrastate trade activities. They also pointed out that there was no evidence showing that this tax had any negative impact on interstate commerce or created any unfair competition between states.