In the 1927 case of St. Louis & Southwestern Railway Company v. Nattin, Tax Collector, the U.S Supreme Court ruled in favor of the railway company. The dispute arose when Louisiana tax authorities attempted to levy taxes on interstate freight cars owned by a railroad company but used and stored temporarily within their state boundaries. The court held that such taxation was unconstitutional as it interfered with interstate commerce, which is under federal jurisdiction according to Article I, Section 8 of the Constitution (the Commerce Clause). This decision reinforced previous rulings that states cannot impose burdensome taxes or regulations on activities related to interstate commerce without violating constitutional principles.

The dissenting opinion in the case of St. Louis & Southwestern Railway Company v. Nattin, Tax Collector argued that the majority's decision was inconsistent with previous rulings and violated principles of federalism by interfering with state taxation powers. The dissent contended that there was no constitutional basis for exempting interstate commerce from state taxes, as long as those taxes were not discriminatory or burdensome to such an extent that they interfered with Congress' power to regulate interstate commerce. They also pointed out inconsistencies between this ruling and past decisions where similar tax laws had been upheld by the court. Furthermore, they believed it was inappropriate for a federal court to intervene in a matter of state taxation without clear evidence of unconstitutional action on part of the State.