In the Central Trust Company v. Kneeland case of 1890, the U.S Supreme Court ruled on a dispute involving taxation and corporate rights. The Central Trust Company, based in New York, owned bonds issued by various counties in Michigan. These bonds were secured by mortgages on real estate located within those counties. The State of Michigan sought to tax these bonds as property situated within its jurisdiction under state law. The trust company argued that this was unconstitutional because it violated their Fourteenth Amendment rights - specifically, they claimed that such taxation deprived them of their property without due process of law and denied them equal protection under the laws. However, the Supreme Court disagreed with this argument and upheld Michigan's right to tax these securities. It concluded that while corporations are considered "persons" for some purposes under constitutional law (such as contract enforcement), they do not have all individual rights guaranteed by the Constitution - including immunity from certain forms of state-level taxation.

In the dissenting opinion for Central Trust Company v. Kneeland, Justice Lamar disagreed with the majority's interpretation of Michigan law and its application to this case. He argued that under Michigan law, a mortgage is not considered absolute ownership but rather a lien on property. Therefore, he contended that the tax assessed by Michigan should be viewed as being levied against the mortgagor’s equity of redemption and not against any interest held by Central Trust Company in New York. The justice further asserted that if there was an error in assessing taxes it was one made under state laws which could only be corrected through state tribunals or legislation, not federal courts. In his view, no constitutional question arose from these proceedings because they were based entirely upon local statutes governing taxation within their jurisdictional limits.