This Supreme Court case involved a dispute between the Auditor of the State of Ohio and the Baltimore & Ohio Railroad Company. The Auditor had issued a warrant to the Railroad Company for the payment of certain taxes, which the Railroad Company refused to pay. The Auditor then brought suit against the Railroad Company in the Supreme Court of Ohio, seeking to recover the taxes. The Railroad Company argued that the taxes were unconstitutional and that the Auditor had no authority to collect them. The Supreme Court of Ohio held that the taxes were constitutional and that the Auditor had the authority to collect them. The Railroad Company then appealed to the Supreme Court of the United States. The Supreme Court affirmed the decision of the Supreme Court of Ohio, holding that the taxes were constitutional and that the Auditor had the authority to collect them. The Court further held that the Railroad Company was liable for the taxes and that the Auditor was entitled to recover them.

In Allen, Auditor, & Another v. Baltimore & Ohio Railroad Company, the Supreme Court was tasked with deciding whether a state tax on railroad companies was constitutional or not. The majority opinion held that it was unconstitutional because it violated the Contract Clause of the Constitution by impairing an existing contract between Maryland and its railroads. Justice Field dissented from this decision and argued that while he agreed with much of what had been said in support of the majority’s position, he believed that there were other considerations which should be taken into account when determining constitutionality. He argued that states have broad powers to impose taxes for public purposes and noted how such taxes are often necessary to fund important government services like education and infrastructure projects. Furthermore, he pointed out how these kinds of taxes can help promote economic development within a state as well as provide revenue for essential public works projects which benefit all citizens equally regardless if they use those services or not. Ultimately Justice Field concluded his dissent by stating his belief that since no one party is being unfairly burdened by this particular tax then it should be considered constitutional under both federal law and precedent set forth in prior cases involving similar issues