The Central of Georgia Railway Company v. Wright case in 1919 involved a dispute over taxation between the railway company and the state of Georgia. The railway company argued that it was being unfairly taxed by the state, as its property within city limits was subject to both municipal and county taxes, while other properties were only subjected to one or the other. The Supreme Court ruled in favor of Wright, Comptroller General of State of Georgia, stating that there is no constitutional principle preventing double taxation and that states have wide discretion when creating tax laws. Therefore, even if a tax law may seem unfair or unequal in its application, it does not necessarily mean it violates any constitutional rights or principles.

In the dissenting opinion for Central of Georgia Railway Company v. Wright, it was argued that the majority's decision to uphold a tax imposed by the state of Georgia on railway companies violated principles of interstate commerce and equal protection under law. The dissent contended that this tax disproportionately affected out-of-state businesses, thereby interfering with interstate commerce in violation of federal law. Furthermore, they believed that because not all corporations were subject to this tax - only those classified as "public service" corporations - it constituted unequal treatment under law. They also expressed concern about potential misuse or abuse of such taxation powers by states if left unchecked.