This case involved a dispute between the Chicago Life Insurance Company and the Auditor of the State of Indiana. The company had been assessed a tax by the state for the years 1877 and 1878. The company argued that the tax was unconstitutional because it violated the Fourteenth Amendment of the United States Constitution. The Fourteenth Amendment states that no state shall deny any person the equal protection of the laws. The Supreme Court held that the tax was constitutional. The Court reasoned that the tax was not discriminatory and did not violate the Fourteenth Amendment. The Court noted that the tax was applied to all insurance companies in the state, regardless of their size or location. The Court also noted that the tax was not excessive and was not a burden on the company. The Court concluded that the tax was constitutional and that the company was liable for the tax. The Court also noted that the company had failed to raise any other constitutional objections to the tax. The Court held that the company was liable for the tax and that the state was entitled to collect it.

In the case of Chicago Life Insurance Company v. Needles, Auditor, the Supreme Court was asked to decide whether or not a state auditor had authority to assess taxes on an insurance company that did business in multiple states. The majority opinion held that the auditor did have such authority and could tax all premiums collected by the company regardless of where they were earned. However, Justice Field dissented from this decision and argued that it violated both due process and equal protection clauses of the Fourteenth Amendment as well as other provisions within Article I Section 8 Clause 1 of Constitution which grants Congress exclusive power over interstate commerce. He further argued that allowing each state to impose its own taxation scheme would create an undue burden for businesses operating across multiple jurisdictions since they would be forced to comply with different regulations in each jurisdiction while also having their profits taxed at varying rates depending on where those profits were made.