The U.S. Supreme Court case American Refrigerator Transit Company v. Hall in 1898 revolved around a dispute over the taxation of personal property located outside of its owner's state of residence. The plaintiff, American Refrigerator Transit Company, was incorporated in Illinois but owned and operated refrigerator cars that were frequently used for interstate commerce and often found themselves situated temporarily within Missouri borders. The defendant, Hall (the tax collector), sought to impose taxes on these cars while they were present within Missouri territory despite their ownership by an out-of-state entity. The court ruled against the transit company, upholding Missouri's right to levy taxes on such properties as long as they had a physical presence or "situs" within the state at any point during the taxable year - even if only temporarily so due to business operations like those conducted by American Refrigerator Transit Company. This decision affirmed states' rights to tax personal property physically present within their boundaries regardless of where it is domiciled or who owns it.

In the dissenting opinion for American Refrigerator Transit Company v. Hall, the justice disagreed with the majority's interpretation of a clause in an interstate commerce contract. The justice argued that this clause was not intended to exempt carriers from liability for negligence but rather to limit their responsibility to specific areas within their control or influence. He believed that such clauses should be interpreted narrowly and strictly against those who seek exemption from liability, especially when it comes to common carriers whose duty is public service. Furthermore, he pointed out inconsistencies between state laws regarding these contracts which could lead to confusion and unfairness if not addressed by federal law or regulation. Therefore, he dissented from the majority's decision absolving the carrier of any fault due its contractual stipulations.