Walling v. Michigan was a United States Supreme Court case that dealt with the issue of whether a state could impose a tax on a foreign corporation that was doing business within its borders. The case was brought by the Michigan Tax Commission against the Walling Manufacturing Company, a foreign corporation that was doing business in Michigan. The Michigan Tax Commission argued that the company was subject to the state's corporate income tax, while the company argued that it was not subject to the tax because it was a foreign corporation. The Supreme Court ultimately sided with the Michigan Tax Commission, ruling that the state had the right to impose a tax on the foreign corporation. The Court held that the state had the power to tax foreign corporations doing business within its borders, and that the tax was not an unconstitutional burden on interstate commerce. The Court also noted that the tax was not discriminatory, as it applied equally to all foreign corporations doing business in the state. The decision in Walling v. Michigan established that states have the power to impose taxes on foreign corporations doing business within their borders. This decision has been cited in numerous subsequent cases, and has been used to support the idea that states have the right to impose taxes on foreign corporations.

Justice Field delivered the dissenting opinion in Walling v. Michigan, arguing that Congress had no authority to pass a law regulating the wages of laborers employed by private contractors on public works projects. He argued that such regulation was beyond the scope of Congressional power and violated states' rights under the Tenth Amendment. Furthermore, he noted that if Congress could regulate labor contracts between private parties for work done on public works projects, it would have similar powers over all other kinds of labor contracts as well - an outcome which he found unacceptable. Justice Field concluded his dissent by noting that while there may be good reasons why some form of wage regulation should exist for workers engaged in government-funded construction projects, this decision should not be made by federal legislators but rather left up to state legislatures who are more familiar with local conditions and better able to craft appropriate regulations accordingly.