In the case of Burr v. The Des Moines Railroad and Navigation Company, the Supreme Court was asked to decide whether a state could tax property owned by a corporation in another state. The plaintiff argued that such taxation violated the Constitution's Commerce Clause, which gives Congress exclusive power over interstate commerce. The court held that states may not impose taxes on property located outside their borders unless it is necessary for public safety or health reasons. Furthermore, even if such taxes are imposed they must be reasonable and nondiscriminatory in order to pass constitutional muster. In this case, since there were no compelling public interests at stake and because Iowa had failed to show any need for its taxing scheme beyond mere revenue generation, the court found it unconstitutional under both federal law and principles of comity between states.

In the case of Burr v. The Des Moines Railroad and Navigation Company, Chief Justice Chase delivered a dissenting opinion in which he argued that the majority had misinterpreted the law. He stated that Congress had not intended to grant immunity from liability for negligence when it granted charters to railroads, as this would be contrary to public policy and common sense. Furthermore, he argued that if such an interpretation were accepted then any corporation could escape responsibility for its own negligence by simply obtaining a charter from Congress. In his view, allowing corporations such broad immunities was unjustified and should not be allowed under existing laws or precedents set by prior cases. Ultimately, Chief Justice Chase concluded that while corporations may have certain privileges due to their special status they are still subject to general rules of law like all other citizens and thus must bear responsibility for their actions just like everyone else does in society.