In the United States Express Company v. Minnesota case of 1911, the Supreme Court ruled on whether a state could tax an interstate commerce company for its operations within that state's borders. The U.S. Express Company was an interstate freight carrier operating in several states, including Minnesota. The State of Minnesota imposed a tax on the company based on its gross earnings from business conducted both inside and outside of the state. The U.S. Express Company argued this taxation violated their rights under the Commerce Clause of the Constitution which prohibits states from interfering with interstate commerce without Congressional approval. However, in a unanimous decision led by Justice Oliver Wendell Holmes Jr., it was held that while direct taxes upon interstate commerce are unconstitutional, indirect taxes such as those levied by Minnesota were permissible if they did not discriminate against or place undue burdens upon interstate businesses compared to intrastate ones. This ruling upheld Minnesota’s right to impose such taxes and set precedent for future cases involving similar issues between states' rights and federal jurisdiction over commercial activities crossing state lines.

In the dissenting opinion for United States Express Company v. Minnesota, 1911, it was argued that the state of Minnesota had not exceeded its jurisdiction in taxing an interstate commerce company. The dissenting justices believed that while Congress has exclusive power over interstate commerce, this does not prevent a state from imposing taxes on businesses operating within their borders - even if these businesses also operate across state lines. They contended that as long as the tax is applied fairly and does not interfere with federal regulation or discriminate against interstate commerce, it should be considered valid under the Constitution's Commerce Clause. Therefore, they disagreed with the majority's ruling which held Minnesota’s taxation unconstitutional because they saw it as a legitimate exercise of states' rights to levy taxes on companies benefiting from operations within their jurisdictions.