In the case of Atchison, Topeka & Santa Fe Railway Company v. Moore (1913), the U.S Supreme Court dealt with a dispute over taxation. The state of Oklahoma had imposed taxes on railway companies based on their total mileage within the state. However, Atchison, Topeka & Santa Fe Railway Company argued that this tax was unconstitutional as it included property located outside of Oklahoma's jurisdiction and thus violated due process rights under Fourteenth Amendment. The court ruled in favor of Moore - representing Oklahoma - stating that while some properties were indeed out-of-state, they were integral to operations within the state and therefore could be taxed accordingly without violating constitutional rights.

The dissenting opinion in the case of Atchison, Topeka & Santa Fe Railway Company v. Moore argued that the majority's decision was a misinterpretation of the Commerce Clause and an overreach of federal power. The dissenters believed that states should have more authority to regulate commerce within their own borders, including railroads. They contended that if a state law does not directly conflict with a federal law or impede interstate commerce, it should be allowed to stand. In this particular case, they felt that Oklahoma's regulation requiring trains to stop at county seats did not interfere with interstate trade but rather promoted safety and convenience for local passengers and businesses. Therefore, they disagreed with the majority ruling which struck down this state law as unconstitutional interference with interstate commerce.