In the 1914 case Wells Fargo & Company Express v. Ford, the United States Supreme Court dealt with a dispute over taxation of personal property located in different states. The plaintiff, Wells Fargo & Co., argued that they were being double taxed on their tangible personal property by both Minnesota and South Dakota. They claimed this violated the Due Process Clause of the Fourteenth Amendment which prohibits any state from depriving "any person of life, liberty or property without due process of law." However, the court ruled against them stating that there was no violation as each state had jurisdiction to tax all personal properties within its borders regardless if it is also taxable in another state. Therefore, even though some items may be subject to taxation in more than one place because they are temporarily located elsewhere at times during a year for business purposes does not constitute double taxation under constitutional law.

In the dissenting opinion for Wells Fargo & Company Express v. Ford, it was argued that the majority's decision to uphold a tax imposed by Oklahoma on gross receipts of express companies operating in the state was incorrect. The dissenting justices believed this tax violated both due process and equal protection clauses of the Fourteenth Amendment because it unfairly targeted certain businesses while exempting others from similar taxation. They also contended that such a tax could potentially discourage interstate commerce as it placed an undue burden on out-of-state corporations conducting business within Oklahoma's borders. Furthermore, they disagreed with the majority’s interpretation of what constituted “property” under law, arguing that intangible assets like contracts should not be considered property subject to taxation.