In the case of Pullman Company v. Knott, Comptroller of the State of Florida in 1914, the Supreme Court ruled on a dispute involving taxation and interstate commerce. The Pullman Company operated sleeping cars that traveled through multiple states including Florida. The state attempted to tax each car for its full value rather than just taxing for the portion of time spent within Florida's borders. The company argued this was an unfair burden on interstate commerce and violated their Fourteenth Amendment rights by depriving them property without due process. The Supreme Court sided with Florida, ruling that it had not imposed an undue burden on interstate commerce nor deprived Pullman Company of property without due process under law as per Fourteenth Amendment protections. It held that since these cars were regularly present in the state and used extensively there, they constituted a form of tangible personal property subject to local taxation.

In the dissenting opinion for Pullman Company v. Knott, Justice Holmes disagreed with the majority's decision to strike down Florida's tax on Pullman cars operating within its borders. He argued that states should have the right to levy taxes on businesses operating within their jurisdiction as long as they do not interfere with interstate commerce or violate any other constitutional provisions. In his view, this was a matter of state sovereignty and did not infringe upon federal authority over interstate commerce because it was simply a tax levied by Florida on property located in the state at midnight of each day during which such car is found within its limits. Furthermore, he contended that there were no grounds for considering this taxation discriminatory against out-of-state companies since it applied equally to all sleeping cars operated in Florida regardless of where they originated from.