In Quackenbush v. United States (1899), the U.S. Supreme Court ruled that a federal court could not issue an injunction to prevent the collection of taxes by state officials, even if those taxes were allegedly unconstitutional. The case involved a dispute between New York resident Henry Quackenbush and the U.S government over tax levies on his property in California for unpaid customs duties. He sought an injunction from a federal circuit court to stop California tax collectors from seizing his property, arguing that he had already paid these duties and thus was being taxed twice for the same thing - which violated his constitutional rights against double jeopardy and deprivation of property without due process of law. However, Justice Rufus W Peckham delivered the unanimous decision stating that while it is true there are circumstances where federal courts can intervene in state taxation matters, this was not one such instance as no irreparable injury would be caused by allowing state proceedings to continue uninterrupted. Furthermore, he noted that taxpayers have adequate remedies under state law for any alleged wrongs committed during taxation processes.

In the dissenting opinion for Quackenbush v. United States, it was argued that the majority's decision to uphold a tax on legacies and distributive shares of personal property in cases where the deceased had made a will was incorrect. The dissenting justices believed this interpretation went against previous rulings which held that such taxes were not within Congress' power to impose under Article I, Section 8 of the Constitution. They further contended that these types of taxes should be considered direct taxes rather than excise or indirect ones as they are levied upon property itself and not its use or transfer. Therefore, according to them, these legacy and succession duties were unconstitutional unless apportioned among states based on their populations as required by Article I, Section 2 for all direct taxation.