In Chesapeake & Ohio Railway Company v. Miller, Auditor, the Supreme Court of the United States was asked to decide whether the state of Ohio had the right to tax the property of a railroad company located in the state. The railroad company argued that the tax was unconstitutional because it violated the Commerce Clause of the United States Constitution. The Court held that the tax was constitutional because it was a valid exercise of the state's power to tax property within its borders. The Court also held that the tax did not violate the Commerce Clause because it was not a tax on interstate commerce. The Court noted that the tax was imposed on the property of the railroad company, not on the company's activities in interstate commerce. The Court concluded that the tax was a valid exercise of the state's power to tax property within its borders and did not violate the Commerce Clause.

In the case of Chesapeake & Ohio Railway Company v. Miller, Auditor, the Supreme Court was asked to decide whether a state could tax railroad companies for their property located within its borders. The majority opinion held that states had no power to impose such taxes on interstate commerce and thus overturned an earlier decision by the Indiana Supreme Court which had allowed taxation of railroads in this manner. Justice Field dissented from this ruling, arguing that while Congress has exclusive authority over interstate commerce it does not have exclusive authority over taxation related thereto. He argued further that since states are sovereign entities they should be able to exercise their right to tax businesses operating within their boundaries regardless of any involvement with interstate commerce; otherwise they would be deprived of one source of revenue necessary for providing services and maintaining infrastructure essential for economic growth and development.