In the case of Williams v. Fears, 1900, the U.S Supreme Court ruled in favor of a Georgia law that imposed a tax on agents who recruited workers to leave the state for employment elsewhere. The plaintiff argued that this law violated his rights under both the Commerce Clause and Fourteenth Amendment's Equal Protection Clause. However, Justice Edward Douglass White Jr., writing for the majority, held that states have an inherent power to regulate their internal affairs and protect their citizens' welfare; thus they can impose such taxes without violating constitutional principles. He further stated that recruiting laborers is not commerce but merely impacts it indirectly so does not fall within federal jurisdiction under the Commerce Clause. As per Fourteenth Amendment claim, he noted there was no discrimination as all recruiters were taxed equally regardless of destination or purpose behind recruitment.

In the dissenting opinion for Williams v. Fears, Justice John Marshall Harlan argued that the tax imposed by Georgia on employment agencies recruiting workers for out-of-state jobs was unconstitutional. He believed it violated both the Commerce Clause and Fourteenth Amendment of the Constitution. According to him, this law interfered with interstate commerce as it essentially taxed individuals seeking employment outside of Georgia, which could discourage such activity. Furthermore, he saw this as a violation of equal protection under law because it unfairly targeted one specific class of citizens - those looking for work in other states through these agencies - without a justifiable reason related to public health or safety concerns.