In the case of Union Refrigerator Transit Company v. Lynch, 1899, the Supreme Court ruled on a dispute involving interstate commerce and tax law. The Union Refrigerator Transit Company was an out-of-state corporation that owned refrigerated cars used to transport perishable goods across state lines. Kentucky imposed taxes on these cars while they were within its borders, which the company challenged as unconstitutional under both due process and commerce clause grounds. The Supreme Court upheld Kentucky's right to impose such taxes. It reasoned that although the transit company was engaged in interstate commerce, it still made use of local services and infrastructure provided by Kentucky - including police protection for its property - thus justifying taxation by the state. Furthermore, it held that this did not constitute double taxation because each state where these cars operated had a similar justification for imposing their own taxes; hence there would be no violation of due process rights even if every state chose to do so.

In the dissenting opinion for Union Refrigerator Transit Company v. Lynch, Justice Harlan disagreed with the majority's interpretation of a clause in an interstate commerce contract that exempted the carrier from liability for negligence. He argued that such clauses should not be interpreted to absolve carriers from their own negligence or misconduct unless explicitly stated in clear and unequivocal terms. In his view, public policy required carriers to exercise due care and diligence in transporting goods entrusted to them by shippers; therefore, any contractual provision relieving them of this obligation was contrary to good morals and sound public policy. Furthermore, he contended that if there were any doubt about how such a clause should be interpreted, it must be resolved against the corporation which prepared it and inserted it into its contracts with individuals who had no voice as to its terms.