The U.S. Supreme Court case Wisconsin Department of Revenue v. William Wrigley, Jr., Co., 1991 revolved around the issue of state taxation on out-of-state corporations and their activities within a state's borders. The William Wrigley Jr. Company, an Illinois-based chewing gum manufacturer, had sales representatives in Wisconsin but did not have any manufacturing or retail facilities there. The State of Wisconsin attempted to tax the company for its business activities conducted within the state under Public Law 86-272 which protects companies from being taxed by states where they only solicit orders for tangible goods. However, the court ruled in favor of Wrigley stating that ancillary activities such as providing replacement products for retailers and storing merchandise locally were still protected under P.L 86-272 as these actions were considered part of solicitation process rather than separate taxable business operations.

In the dissenting opinion for Wisconsin Department of Revenue v. William Wrigley, Jr., Co., Justice Blackmun argued that the majority's interpretation of "solicitation" was too narrow and inconsistent with previous court decisions. He believed that all activities conducted by a company in a state should be considered when determining whether it has established nexus for tax purposes, not just those directly related to soliciting sales. This includes activities like providing customer service or maintaining inventory within the state. Furthermore, he disagreed with the majority's decision to exclude certain types of promotional activity from consideration as solicitation because they are not explicitly mentioned in Public Law 86-272 (a law which provides protection against taxation for companies whose only business activity in a state is solicitation). In his view, this approach ignores Congress' intent to provide broad protections against discriminatory taxation practices.