In the case of California v. Southern Pacific Company, 1893, the U.S. Supreme Court was asked to determine whether a state could impose taxes on interstate commerce companies that were not based in their jurisdiction but operated within it. The Southern Pacific Company had been taxed by California for operating railroads across its territory even though it was incorporated in Kentucky. The company argued this violated the Commerce Clause of the Constitution which gives Congress exclusive power over interstate commerce and prohibits states from interfering with such trade. The court ruled in favor of Southern Pacific Company stating that while states have broad powers to tax businesses within their borders, they cannot interfere with or place burdens on interstate commerce as this is under federal jurisdiction according to Article I Section 8 of the Constitution (the Commerce Clause). This decision reinforced limits on state taxation powers and affirmed federal supremacy over matters related to interstate commerce.

In the dissenting opinion for California v. Southern Pacific Company, Justice Field argued that corporations should not be granted the same rights as individuals under the Fourteenth Amendment's Equal Protection Clause. He contended that this clause was intended to protect former slaves and other marginalized groups from discrimination, not to shield corporations from state regulations. Furthermore, he believed that granting such protections to corporations would undermine states' abilities to regulate businesses in a manner beneficial for their citizens. This could lead to an imbalance of power favoring large companies over individual citizens and local governments. Thus, he disagreed with the majority ruling which extended these constitutional protections to corporate entities.