In the Central Land Company v. Laidley case of 1894, the U.S. Supreme Court ruled on a dispute over land ownership in West Virginia. The Central Land Company claimed that it owned certain lands under an old patent and had been paying taxes on them for years, while John T. Laidley argued he held title to these lands through a more recent purchase from another party who also claimed ownership under an older patent than that of the company's claim. The court decided in favor of Laidley, stating that tax payments alone do not establish or confirm title to property if there is no legal basis for claiming such title initially; moreover, they cannot be used as evidence against other valid claims based on superior titles or patents unless those parties have acknowledged and acquiesced to such payments being made by others with inferior claims.

In the dissenting opinion for Central Land Company v. Laidley, Justice Brewer argued that the majority's decision to uphold a West Virginia law taxing out-of-state corporations at higher rates than in-state ones was unconstitutional. He contended that this violated both the Equal Protection Clause and Commerce Clause of the Constitution by discriminating against interstate commerce and treating similarly situated entities differently based on their state of incorporation. Furthermore, he believed it infringed upon federal power to regulate interstate commerce by allowing states to impose burdensome taxes on out-of-state businesses. Thus, he disagreed with the majority's interpretation of constitutional provisions regarding taxation and commercial regulation.