The U.S. Supreme Court case Atlantic Coast Line Railroad Company v. State of Georgia in 1913 revolved around the issue of whether a state could regulate and limit the rates that railroads charged for intrastate commerce without violating the Commerce Clause of the Constitution, which gives Congress power to regulate interstate commerce. The Atlantic Coast Line Railroad Company argued that Georgia's rate regulations interfered with interstate trade by making it less profitable, thus infringing upon federal authority over such matters. However, the Supreme Court ruled against them, upholding Georgia's right to set railroad rates within its borders as long as those regulations did not directly conflict with any federal laws or policies regarding interstate commerce. This decision reinforced states' rights to control local economic activities while also affirming federal supremacy in regulating broader commercial interactions.

In the dissenting opinion for Atlantic Coast Line Railroad Company v. State of Georgia, Justice Holmes argued that the state had not violated any constitutional rights by imposing a tax on railroads operating within its borders. He contended that it was within the power of states to levy taxes as they saw fit and that this did not infringe upon interstate commerce or violate equal protection laws. The justice maintained that there was no evidence to suggest discriminatory treatment against out-of-state corporations, nor were there grounds to claim an undue burden on interstate commerce due to taxation differences between in-state and out-of-state companies. Furthermore, he asserted that if every difference in taxation could be challenged under equal protection claims, then all state taxing powers would essentially become nullified.