The Canton Railroad Co. v. Rogan case in 1950 revolved around a dispute between the Canton Railroad Company and the State Tax Commission of Maryland over property tax assessments. The railroad company argued that its properties were assessed at a higher rate than other commercial and industrial properties, violating their right to equal protection under the Fourteenth Amendment of the U.S Constitution. The Supreme Court ruled in favor of the railroad company, stating that intentional systematic undervaluation by state officials of other taxable property could not constitute a discriminatory practice against railroads within constitutional tolerances for tax assessment purposes. Therefore, it was concluded that there had been an unconstitutional discrimination against interstate commerce.

The dissenting opinion in the case of Canton Railroad Co. v. Rogan et al., argued that the majority's decision to strike down Maryland's tax on out-of-state corporations was incorrect and inconsistent with previous rulings by the Court. The dissenters believed that Maryland had a right to impose such a tax, as it did not discriminate against interstate commerce or violate any constitutional provisions. They pointed out that other states imposed similar taxes without issue and suggested that this ruling could have far-reaching implications for state taxation policies across the country. Furthermore, they disagreed with the majority's interpretation of what constituted "fair apportionment" under law, arguing instead for a more flexible approach based on each state’s unique circumstances.