In the case of The Pullman Company v. Knott, as Comptroller of the State of Florida in 1916, the U.S Supreme Court ruled on a dispute involving taxation by states on interstate commerce. The Pullman Company was an Illinois-based corporation that manufactured and operated sleeping cars for railroads across several states including Florida. The state had imposed a tax on each car owned or operated by any sleeping car company within its borders. However, Pullman argued this violated their constitutional rights under both Due Process and Commerce Clauses because it interfered with interstate commerce. The Supreme Court upheld Florida's right to levy such taxes ruling that they did not infringe upon federal jurisdiction over interstate commerce nor violate due process rights provided under Fourteenth Amendment protections since these were property taxes levied equally among all similar businesses operating within the state’s boundaries regardless if they engaged in intrastate or interstate business activities.

In the dissenting opinion for The Pullman Company v. Knott, Justice Holmes argued that the tax imposed by Florida on sleeping cars was not an unconstitutional burden on interstate commerce. He contended that it was a legitimate exercise of state power to impose taxes on property within its jurisdiction and disagreed with the majority's interpretation of previous cases regarding taxation and interstate commerce. He believed that these cases did not establish a principle prohibiting states from taxing personal property used in interstate business if such property had become part of the general mass of property in the state. Furthermore, he pointed out inconsistencies between this decision and other rulings where similar taxes were upheld as constitutional when levied against railroad companies or telegraph lines operating across state borders.