In the case of Department of Revenue of Washington v. Association of Washington Stevedoring Companies et al., 1977, the Supreme Court ruled on whether a state tax imposed on stevedoring companies for loading and unloading cargo was constitutional. The court held that this tax did not violate the Commerce Clause or Due Process Clause as claimed by the Association of Washington Stevedoring Companies. The court reasoned that while interstate commerce is generally immune from state taxation, it does not mean all activities connected with such commerce are also immune. In this case, stevedores were providing local services within a port and thus could be subject to local taxation without interfering with interstate commerce or violating due process rights.

In the dissenting opinion for the Department of Revenue of Washington v. Association of Washington Stevedoring Companies et al., Justice Brennan, joined by Justices Stewart and Marshall, argued that the tax imposed on stevedoring companies was not a violation of federal law or constitutionally impermissible. They contended that it did not discriminate against interstate commerce as it applied equally to both in-state and out-of-state businesses involved in loading and unloading cargo from ships. The dissent also disagreed with the majority's interpretation that Congress intended to preempt state taxation in this area through its regulation of longshoremen’s activities under federal maritime laws. Instead, they believed there was no clear evidence showing such intent from Congress. Furthermore, they asserted that even if some burden resulted from this tax on interstate commerce, it would be justified by significant local benefits provided by these businesses' operations within Washington State.