The U.S. Supreme Court case Adams Express Company v. Kentucky in 1896 revolved around the issue of interstate commerce and state taxation rights. The Adams Express Company, an interstate carrier, was taxed by the state of Kentucky for goods transported within its borders that originated from other states. The company argued this tax violated the Commerce Clause of the Constitution which prohibits states from interfering with interstate commerce without congressional approval. However, the court ruled in favor of Kentucky stating that once goods have reached their destination and are no longer part of interstate transit, they can be subjected to local taxes just like any other property within a state's jurisdiction.

In the dissenting opinion for Adams Express Company v. Kentucky, Justice Harlan argued that the majority's decision was inconsistent with previous rulings of the Court and violated principles of federalism by allowing states to tax interstate commerce. He contended that a state cannot impose taxes on activities beyond its jurisdiction, such as interstate transportation services provided by express companies like Adams Express Company. According to him, this would lead to multiple taxation from different states which could potentially cripple businesses engaged in interstate commerce. Furthermore, he asserted that it is Congress' responsibility under the Commerce Clause of Constitution to regulate and control any burdens on interstate trade including taxation issues rather than individual states'. Therefore, he disagreed with majority's ruling upholding Kentucky’s right to tax an out-of-state company for business conducted within its borders.