The U.S. Supreme Court case Walls, Attorney General of the State of Wyoming, et al. v. Midland Carbon Company et al., 1920 revolved around a dispute over taxation and mineral rights in the state of Wyoming. The Midland Carbon Company had leased land from the Union Pacific Railroad for oil extraction purposes but refused to pay taxes on it claiming that they were not owners but merely lessees and therefore should be exempted from property tax under existing laws at that time which only taxed owners of real estate properties. However, the State argued that since they were extracting valuable minerals (oil) from beneath these lands, this constituted ownership as per their interpretation of law and hence liable to pay taxes on it. The Supreme Court ruled in favor of Midland Carbon Company stating that while leasing did give them certain rights over usage or possession temporarily during lease period; it didn't constitute actual ownership as defined by law because once lease term ended all such rights would revert back to original owner i.e., Union Pacific Railroad who was already paying property tax on said land parcels thus avoiding double taxation situation.

The dissenting opinion in the case of Walls v. Midland Carbon Company argued that the majority's decision to uphold a Wyoming law imposing taxes on out-of-state corporations was unconstitutional. The dissenters believed that this law violated the Commerce Clause of the U.S Constitution, which gives Congress exclusive power over interstate commerce. They contended that by taxing these corporations based on their total capital, regardless of how much business they conducted within Wyoming, the state was effectively regulating and burdening interstate commerce. This taxation scheme could potentially discourage companies from doing business across state lines or unfairly penalize those who do so extensively, thus interfering with free trade among states as envisioned by framers of constitution. Furthermore, they disagreed with majority’s interpretation about due process clause under Fourteenth Amendment; arguing it should protect businesses from such arbitrary and discriminatory taxation practices.