In the 1922 case of St. Louis Cotton Compress Company v. State of Arkansas, the U.S Supreme Court was tasked with determining whether a state could impose a tax on an out-of-state corporation for goods stored within its borders without violating the Due Process Clause or Commerce Clause of the Constitution. The St. Louis Cotton Compress Company, based in Missouri but operating warehouses in Arkansas, challenged an Arkansas law that imposed taxes on cotton bales stored within their facilities arguing it interfered with interstate commerce and violated due process rights under Fourteenth Amendment. The court ruled against St. Louis Cotton Compress Company stating that states have authority to levy taxes on personal property located within their jurisdiction even if owned by non-residents or foreign corporations as long as they are not involved in interstate transit at time of taxation; hence no violation occurred regarding either clause cited by company. This decision affirmed states' power to tax property held within their boundaries regardless owner's residence status while also clarifying limits placed upon such powers by federal constitution when dealing with matters related to interstate commerce and due process protections.

The dissenting opinion in the case of St. Louis Cotton Compress Company v. State of Arkansas argued that the majority's decision was a departure from established principles regarding interstate commerce and taxation. The dissent contended that the tax imposed by Arkansas on cotton stored within its borders, even if destined for export, did not constitute an unconstitutional burden on interstate commerce as it was levied equally upon all cotton regardless of its final destination - whether domestic or foreign markets. They believed this to be a legitimate exercise of state power over property within its jurisdiction and not discriminatory against out-of-state interests or interfering with federal authority over international trade. Furthermore, they disagreed with the majority's interpretation that such taxes were prohibited indirect exports duties under Article I Section 10 Clause 2 of Constitution; instead viewing them as permissible internal taxes applied non-discriminatorily before goods became exports.