In the case of Susquehanna Power Company v. State Tax Commission of Maryland, the Supreme Court was tasked with deciding whether a state could tax an out-of-state corporation for property located within its borders but used in connection with business conducted primarily outside that state. The Susquehanna Power Company, incorporated in Pennsylvania and operating hydroelectric power plants on the Susquehanna River, sold most of its electricity to companies outside Maryland despite some equipment being located there. The State Tax Commission assessed taxes based on this equipment's value. The company contested these taxes arguing it violated their Fourteenth Amendment rights by taxing property beyond Maryland’s jurisdictional reach. However, the court ruled against them stating that states have authority to levy such taxes as long as they are not discriminatory or disproportionate to benefits received from the state where assets are situated. This decision upheld principles of federalism and affirmed states' rights to tax businesses operating within their borders even if those operations extend beyond state lines.

The dissenting opinion in the case of Susquehanna Power Company v. State Tax Commission of Maryland argued that the majority's decision was inconsistent with prior rulings on similar issues, particularly those involving interstate commerce and taxation. The dissenting justices believed that the tax imposed by Maryland on the power company, which operated across state lines, was not an unfair burden or discriminatory against interstate commerce as it applied equally to all corporations doing business within its borders regardless of whether they were domestic or foreign entities. They contended that states should have authority over their own fiscal affairs without interference from federal courts unless there is a clear violation of constitutional rights. Furthermore, they asserted that this ruling could potentially disrupt state revenue systems and create uncertainty for businesses operating in multiple states due to differing interpretations regarding what constitutes fair taxation under these circumstances.