The Central Pacific Railway Co. et al. v. Alameda County et al., 1931, was a case that revolved around the taxation of railway companies in California by local counties and municipalities. The Supreme Court ruled in favor of the Central Pacific Railway Company, stating that under an agreement made with Congress during their formation, they were exempt from certain types of state and local taxes due to federal subsidies received for constructing transcontinental railroads across America's western frontier. This decision upheld previous rulings which had established this precedent and clarified its application to specific forms of property tax levied against railroad properties within these jurisdictions.

In the dissenting opinion for Central Pacific Railway Co. et al. v. Alameda County et al., Justice Stone argued that the majority's decision to allow California counties to tax federal land grants given to railway companies was inconsistent with previous court rulings and violated constitutional principles of intergovernmental immunity from taxation. He contended that these lands were granted by Congress under an implied condition of exemption from state and local taxation until they were sold or otherwise disposed of by the railroad company, as a means to aid in constructing transcontinental railroads. The justice believed this interpretation was supported by both legislative history and prior Supreme Court decisions, which had consistently held that states could not interfere with federal instrumentalities or property without express congressional consent.