In the case of Central of Georgia Railway Company v. Wright, Comptroller-General of Georgia (1907), the U.S. Supreme Court was asked to determine whether a state tax on railroad companies violated the Commerce Clause or Fourteenth Amendment due process rights. The State of Georgia had imposed a tax on gross receipts from interstate commerce and intrastate business operations by railroads operating within its borders. The Central of Georgia Railway Company challenged this law, arguing that it interfered with interstate commerce and deprived them their property without due process. The court ruled in favor of Wright, upholding the constitutionality of the state's taxation scheme. It found no violation under either clause as long as taxes were not discriminatory against out-of-state entities or burdensome to interstate commerce beyond what would be considered fair apportionment for services provided by the state. This decision affirmed states' power to levy taxes on businesses operating within their jurisdiction even if they are involved in both intra- and inter-state trade activities; however, such taxation must not discriminate against or unduly burden interstate commerce.

The dissenting opinion in the Central of Georgia Railway Company v. Wright case argued that the majority's decision was inconsistent with previous rulings regarding tax assessments on railroad properties. The dissent, led by Justice Harlan, contended that there was no evidence to suggest any intentional discrimination against interstate commerce or violation of equal protection laws as claimed by the railway company. They believed that it is within a state's power to determine how property should be valued for taxation purposes and this does not necessarily equate to an unfair burden on interstate commerce. Furthermore, they asserted that if every assessment higher than true value were deemed discriminatory, then almost all assessments would fall under this category since most are above actual cash value due to various reasons such as ensuring adequate revenue collection among others.