In the Southern Pine Lumber Company v. Ward case of 1907, the U.S Supreme Court ruled in favor of Southern Pine Lumber Company, stating that a state could not impose taxes on goods destined for export to foreign countries. The State of Texas had imposed an ad valorem tax on lumber held by the company awaiting shipment to Mexico. The court found this action unconstitutional as it violated Article I, Section 10 of the Constitution which prohibits states from imposing duties on exports without Congress's consent. This ruling reinforced that taxation power is limited and cannot interfere with commerce among states or with foreign nations.

The dissenting opinion in the Southern Pine Lumber Company v. Ward case argued that the state of Texas did not have jurisdiction to tax property located outside its borders, even if it was owned by a company operating within the state. The justice contended that such taxation violated principles of interstate commerce and due process under the U.S. Constitution. He further asserted that while states can tax companies based on their operations within their boundaries, they cannot extend this power to assets or properties situated elsewhere as these are beyond their legal reach and control. This view emphasized respect for territorial limits of each state's taxing authority and protection against potential double taxation where multiple states could claim taxes on same property based on different justifications.