The U.S. Supreme Court case White, Treasurer, et al. v. Mechanics Securities Corporation in 1925 revolved around the issue of taxation and its potential violation of due process under the Fourteenth Amendment. The state treasurer of Ohio had imposed a tax on foreign corporations for holding mortgages on real estate within the state, which was challenged by Mechanics Securities Corporation as unconstitutional discrimination against interstate commerce and a deprivation of property without due process of law. The court ruled in favor of White (the State), upholding that states have wide discretion to classify taxpayers for purposes related to public welfare or public policy objectives unless it is palpably arbitrary or discriminatory. It further held that taxes are not necessarily invalid because they affect interstate commerce; only if they directly burden such commerce do they become unconstitutional. In this case, since the tax did not directly burden interstate commerce but merely affected it incidentally through taxing an activity carried out within Ohio's jurisdiction (i.e., holding mortgages), it was deemed constitutional.

In the dissenting opinion for White, Treasurer, et al. v. Mechanics Securities Corporation, Justice Holmes argued that the majority's decision was based on a misinterpretation of Ohio state law and its application to federal bankruptcy proceedings. He contended that under Ohio law, a tax lien could not be considered an asset in bankruptcy unless it had been assessed before the filing date. In this case, he pointed out that taxes were assessed after the corporation filed for bankruptcy; therefore they should not have been included as part of its assets available to creditors during liquidation process. Furthermore, he disagreed with majority’s view about supremacy clause stating federal laws do not always supersede state laws especially when dealing with property rights issues such as taxation which are traditionally within states' jurisdictional purview.