In the case of Pullman Company v. Richardson, the United States Supreme Court in 1922 ruled on a dispute between The Pullman Company and the State of California regarding taxation. The state had imposed taxes on Pullman's "capital stock" which was primarily composed of personal property such as sleeping cars that were frequently moving across state lines. The company argued this tax violated both its due process rights under the Fourteenth Amendment and also infringed upon interstate commerce regulations by taxing assets not permanently located within California. The Supreme Court sided with Pullman, ruling that while states have broad powers to levy taxes, they cannot do so in a way that interferes with interstate commerce or violates constitutional protections against arbitrary deprivation of property without due process. This decision reinforced limitations on state power to tax businesses operating across multiple jurisdictions.

The dissenting opinion in the case of Pullman Company v. Richardson argued that the tax imposed by California on Pullman's sleeping cars was not unconstitutional. The justice disagreed with the majority's view that this tax violated interstate commerce laws, arguing instead that it was a legitimate exercise of state power to levy taxes on property within its jurisdiction for public purposes. He further contended that such taxation did not interfere with interstate commerce as long as it remained non-discriminatory and proportional to the value of property taxed within the state boundaries. Therefore, he believed there were no grounds for declaring this particular tax invalid under federal law or constitution.