In the case of Virginia v. Imperial Coal Sales Co., Inc., 1934, the Supreme Court was asked to decide on a dispute over taxation between the state of Virginia and Imperial Coal Sales Company. The coal company had purchased coal from mines in Kentucky and West Virginia, which it then sold to customers in other states without ever storing or using it within Virginia's borders. However, because its business office was located in Richmond, VA, the state sought to tax these transactions as if they were conducted within its jurisdiction. The court ruled that this violated both due process rights under the Fourteenth Amendment and interstate commerce regulations since no part of these transactions occurred within Virginia’s boundaries nor did they use any services provided by the state for their completion. Therefore, imposing such taxes would be an unfair burden on interstate commerce.

The dissenting opinion in the case of Virginia v. Imperial Coal Sales Co., Inc. argued that the state of Virginia did not have jurisdiction over a coal company based in New York for taxes on sales made to customers outside of Virginia, even though the coal was mined within its borders. The justice contended that such taxation violated both due process and interstate commerce clauses as outlined by the U.S Constitution. They believed it was unjust for a state to impose tax obligations on an entity operating primarily outside its territory, especially when transactions occurred entirely beyond its boundaries with no direct benefit or service provided by said state. Furthermore, they expressed concern about potential harm this ruling could cause to interstate commerce if other states followed suit and imposed similar taxes on out-of-state businesses exploiting their resources.