In the case of Pullman Company v. Adams in 1902, the United States Supreme Court ruled on a dispute involving interstate commerce and state taxation laws. The Pullman Company, which manufactured railroad cars in Illinois but leased them to railroads operating across various states, was challenged by Mississippi tax authorities who sought to levy taxes on those cars used within their jurisdiction. The company argued that this constituted an interference with interstate commerce and thus violated federal law. However, the Supreme Court disagreed with Pullman's argument and upheld Mississippi's right to impose such taxes. In its decision, it reasoned that while states cannot directly regulate or impede interstate commerce - a power reserved for Congress under the Constitution - they can indirectly influence it through legitimate exercises of their taxing powers as long as these do not create direct burdens upon it.

In the dissenting opinion for Pullman Company v. Adams, it was argued that the majority's decision to uphold a tax on sleeping cars operated by non-residents in Mississippi violated both the Due Process and Commerce Clauses of the Constitution. The dissent contended that because these cars were not permanently located within Mississippi, but rather traveled through multiple states as part of interstate commerce, they should not be subject to taxation by any one state. Furthermore, it was asserted that this tax placed an unfair burden on out-of-state businesses and disrupted free trade among states. Therefore, according to this view, such a tax is unconstitutional under both clauses mentioned above.