In the Wilkes County v. Coler case of 1900, the U.S Supreme Court ruled in favor of Wilkes County, North Carolina. The dispute arose when a federal tax collector named Nathan O. Coler attempted to collect taxes from the county on bonds that were issued during Reconstruction after the Civil War. These bonds were intended for railroad construction but had been declared void by an amendment to North Carolina's constitution in 1875 because they were fraudulently obtained and misused by corrupt officials during this period known as "The Carpetbagger Era". The court held that since these bonds were not legally valid obligations of the state or its subdivisions under state law due to their fraudulent nature and subsequent nullification, they could not be taxed by federal authorities either.

In the dissenting opinion for Wilkes County v. Coler, Justice Harlan argued that the majority's decision to uphold a tax imposed by Georgia on sleeping car companies operating within its borders was inconsistent with previous rulings of the Court. He contended that this tax was not an excise or privilege tax but rather a property tax, which violated both state law and the Constitution as it discriminated against interstate commerce. The justice further asserted that if such taxes were allowed to stand, they could potentially cripple interstate commerce by subjecting it to multiple taxation from different states where businesses operate. Therefore, he believed that this case should have been decided in favor of Wilkes County instead of upholding Georgia’s right to impose such a discriminatory and burdensome tax.