In the 1935 case of Rickert Rice Mills, Inc. v. Fontenot, Collector of Internal Revenue, the U.S Supreme Court was tasked with determining whether a tax imposed on rice millers for processing and selling their products was constitutional under the Fifth Amendment's due process clause. The plaintiff argued that this tax unfairly targeted them as it did not apply to other businesses involved in similar activities such as wheat or corn milling. However, the court ruled against Rickert Rice Mills stating that Congress had broad discretion in levying taxes and could choose which industries to target based on its assessment of public interest needs. Therefore, even if some businesses were exempt from certain taxes while others weren't didn't necessarily mean there was a violation of equal protection rights under law unless there is clear evidence showing arbitrary discrimination by Congress.

In the dissenting opinion for Rickert Rice Mills, Inc. v. Fontenot, it was argued that the tax imposed on rice millers by Congress was not a valid exercise of its power to regulate interstate commerce but rather an unlawful attempt to control production within states. The dissenting justices believed that this case represented another instance where the Court had overstepped its bounds and intruded upon state sovereignty in violation of principles established by previous decisions such as Hammer v. Dagenhart and Carter v. Carter Coal Co., which held that regulation of manufacturing or mining activities within states fell outside Congress's Commerce Clause authority because they were not directly related to interstate commerce itself but only indirectly affected it through their impact on supply and demand conditions in national markets for goods produced or mined.