In the 1920 case of St. Louis & East St. Louis Electric Railway Company v. State of Missouri, the Supreme Court was asked to decide on a taxation dispute between the railway company and the state of Missouri. The railway company argued that it should not be subjected to double taxation by both Illinois and Missouri for its operations across state lines, asserting that such an arrangement violated their rights under both federal law and interstate commerce regulations. However, after reviewing previous rulings on similar cases as well as considering arguments from both sides, the court ruled in favor of Missouri's right to tax corporations operating within its borders regardless if they are also taxed by another state for different portions of their operation or property located elsewhere.

In the dissenting opinion for St. Louis & East St. Louis Electric Railway Company v. State of Missouri, the justice argued that the majority's decision was inconsistent with previous rulings regarding interstate commerce and taxation laws. The justice contended that a state should not be allowed to tax an interstate business based on its total value, including property located outside of the taxing jurisdiction, as it interferes with interstate commerce and violates due process rights under the Fourteenth Amendment. Instead, they believed taxes should only apply to property within a state’s borders or activities conducted therein; otherwise it would result in double taxation by multiple states which is unfair and unconstitutional according to prior court decisions.