In the case of Ware and Leland v. Mobile County in 1907, the U.S Supreme Court ruled on a dispute involving tax assessment. The plaintiffs, Ware and Leland, were New York-based cotton merchants who had stored their goods in a warehouse located in Mobile County, Alabama. The county assessed taxes on these goods which led to this lawsuit as the plaintiffs argued that they should not be taxed because they did not have an established business within Alabama state lines. The court held that even though Ware and Leland didn't have a permanent place of business or domicile within Alabama's jurisdiction, their property was still subject to taxation by local authorities since it was physically present there for considerable periods of time during each year. This decision reinforced states' rights to levy taxes on personal property regardless of where its owners reside or conduct most of their business activities.

In the dissenting opinion for Ware and Leland v. Mobile County, Justice Oliver Wendell Holmes Jr. argued that the majority's decision was based on a misinterpretation of Alabama state law regarding tax collection procedures. He contended that the county had not violated any laws by selling property to collect unpaid taxes, as this action was explicitly allowed under existing legislation. Furthermore, he disagreed with the majority's assertion that such sales were unconstitutional because they deprived individuals of their property without due process of law; in his view, these sales constituted an essential part of due process itself by ensuring citizens fulfilled their legal obligations to pay taxes. Thus, he believed it was inappropriate for federal courts to interfere with state-level tax collection efforts unless there were clear indications of fraud or other illegal activities involved.