In the case of Sturges & Burn Manufacturing Company v. Beauchamp in 1913, the U.S Supreme Court was tasked with determining whether a state law that required foreign corporations to consent to service of process on an appointed agent as a condition for doing business within its borders was constitutional. The plaintiff, Sturges & Burn Manufacturing Company, argued that this requirement violated their Fourteenth Amendment rights by depriving them of property without due process and denying them equal protection under the laws. However, the court ruled against them stating that states have broad powers to regulate businesses operating within their boundaries and can impose conditions on those businesses' operations so long as they do not violate any specific federal protections or prohibitions. Therefore, requiring foreign corporations to appoint an agent for service of process did not infringe upon their constitutional rights.

In the dissenting opinion for Sturges & Burn Manufacturing Company v. Beauchamp, Justice Holmes argued that the majority's decision was based on a misinterpretation of Alabama law and an overemphasis on technicalities. He contended that while there may have been some irregularity in how the case was handled at trial level, this did not necessarily mean that justice had not been served or that the defendant's rights were violated. The dissent also pointed out inconsistencies in how similar cases had been treated by different courts within Alabama, suggesting a lack of uniformity in interpreting state laws related to debt collection and bankruptcy proceedings. Furthermore, he disagreed with the majority's assertion that certain evidence should have been excluded from consideration during trial due to procedural errors made by lower court judges.