The City of Boston v. Jackson case in 1922 revolved around the issue of taxation and public property. The city of Boston filed a lawsuit against the Treasurer and Receiver General of Massachusetts, arguing that it was unconstitutional for them to impose taxes on public property owned by the city but located outside its limits. The Supreme Court ruled in favor of Massachusetts, stating that under state law, all real estate within its borders is subject to taxation unless explicitly exempted by statute. This includes properties owned by municipalities like Boston even if they are situated outside their territorial boundaries. Therefore, there was no violation of constitutional rights as claimed by the City since states have broad powers over local governments including taxing authority.

In the dissenting opinion for the case City of Boston v. Jackson, it was argued that Massachusetts' law requiring cities and towns to pay a tax on all tangible property located within their boundaries should not apply to public utilities owned by municipalities. The dissenting justices believed that this interpretation violated the principle of intergovernmental tax immunity, which holds that one level of government cannot tax another. They contended that allowing such taxation would give states undue power over local governments and could potentially disrupt essential services provided by these entities. Furthermore, they disagreed with the majority's view that there was no constitutional issue at stake because state legislatures have broad powers to determine municipal liabilities under state law; instead, they asserted this situation did indeed raise significant constitutional concerns about federalism and separation of powers.