In the case of Rogers v. Hennepin County, 1915, the U.S Supreme Court ruled on a dispute involving property taxes. The plaintiff, Mr. Rogers, was an out-of-state resident who owned property in Hennepin County and objected to paying certain local taxes that he believed were unconstitutional under both state law and the Fourteenth Amendment's Equal Protection Clause because they discriminated against non-residents like himself. However, the court disagreed with his argument and upheld the constitutionality of such tax laws by stating that it is within a state’s power to impose different tax rates for residents versus non-residents as long as there is no discrimination between individuals within those categories themselves.

The dissenting opinion in the Rogers v. Hennepin County case argued that the majority's decision to uphold a tax assessment on shares of stock held by a Minnesota resident but issued by corporations outside of Minnesota was incorrect. The dissenters believed this ruling violated the Due Process Clause of the Fourteenth Amendment, which prohibits states from depriving any person "of life, liberty or property without due process of law." They contended that since these stocks were not physically located within Minnesota and did not draw their value from property or business operations within the state, they should not be subject to taxation there. This view maintained that such an imposition constituted an extraterritorial exercise of power by one state over property situated in another – something expressly forbidden under constitutional principles governing federalism and interstate relations.