In the 1934 case of Atchison, Topeka & Santa Fe Railway Co. et al., the U.S Supreme Court was tasked with determining whether a state could impose taxes on an interstate railway company for maintenance and operation costs. The State of California had imposed such a tax on several railway companies, including Atchison, Topeka & Santa Fe Railway Co., which they contested as unconstitutional under the Commerce Clause. The court ruled in favor of the railways, stating that while states have power to tax businesses within their jurisdiction for benefits conferred by them (like police protection), they cannot do so when it interferes with interstate commerce or discriminates against it in favor of local commerce. This decision reinforced federal authority over interstate commerce and limited state taxation powers accordingly.

In the dissenting opinion for the Atchison, Topeka & Santa Fe Railway Co. case in 1934, it was argued that the majority's decision to uphold a state law requiring railroads to provide separate but equal accommodations for black and white passengers violated both due process and equal protection clauses of the Fourteenth Amendment. The dissenters believed that this segregation inherently implied inferiority of African American citizens which contradicted with their constitutional rights as U.S citizens. They also contended that such laws were not truly aimed at promoting public welfare or safety, but rather served as an instrument of racial discrimination. Furthermore, they pointed out inconsistencies in enforcing these laws across different states which further undermined its legitimacy under federal constitution standards.