In the case of Charlotte Harbor & Northern Railway Company v. Welles et al., the Supreme Court was asked to rule on a dispute between a railway company and De Soto County, Florida over taxation. The county had imposed taxes on lands granted by Congress to aid in construction of railroads, which were then transferred to the railway company. The railroad argued that these lands should be exempt from taxation until they were sold or used for purposes other than building railroads under an 1899 Act of Congress. However, the court ruled against them stating that this exemption did not apply as it only referred to land directly granted by Congress and not those subsequently acquired by companies from states who received such grants initially. Therefore, these lands could be subjected to local property tax laws.

In the dissenting opinion for Charlotte Harbor & Northern Railway Company v. Welles et al., it was argued that the majority's decision to uphold a tax assessment on railway property in De Soto County, Florida, violated principles of equal protection under law. The dissenting justices believed that the county had unfairly singled out and discriminated against the railway company by assessing its property at full value while other properties were assessed at only 50% of their actual value. They contended this discrepancy constituted an arbitrary abuse of power and failed to meet standards for uniform taxation as required by state law. Furthermore, they disagreed with the majority's view that courts should not intervene in matters related to tax assessments unless there is clear evidence of fraud or corruption; instead, they asserted judicial review was necessary when fundamental rights were potentially being infringed upon.