In the case of Schwab v. Richardson, as Treasurer of the State of California (1923), the United States Supreme Court addressed a dispute over inheritance tax laws in California. The plaintiff, Schwab, was an heir to a large estate and challenged the state's right to levy taxes on his inherited property that had been located outside of California at the time of death. He argued this violated both due process and equal protection clauses under Fourteenth Amendment rights because it imposed double taxation since he would also have to pay taxes in other states where properties were situated. However, after careful consideration, the court ruled against him stating that there was no violation or infringement upon constitutional rights by such taxation practices from individual states like California. They held that each state has its own jurisdictional power for taxing estates within their boundaries regardless if they are subject to similar levies elsewhere.

In the dissenting opinion for Schwab v. Richardson, Justice Holmes argued that the California law in question did not violate the Fourteenth Amendment's Equal Protection Clause. He contended that it was within a state's rights to regulate businesses and professions as they saw fit, including imposing different tax rates on various types of businesses or occupations. In this case, he believed that California had valid reasons for taxing foreign corporations at a higher rate than domestic ones - namely protecting local industries and promoting economic growth within the state. Furthermore, he pointed out that other states also imposed similar taxes without being deemed unconstitutional. Therefore, he disagreed with the majority ruling striking down California’s discriminatory taxation scheme against foreign corporations.