The Supreme Court case of Chicago, Milwaukee and St. Paul Railway Company v. Minnesota was a dispute between the railway company and the state of Minnesota. The railway company argued that the state had imposed an unconstitutional tax on its property. The state argued that the tax was necessary to fund public improvements and was not an unconstitutional burden on the company. The Supreme Court ruled in favor of the railway company, finding that the tax was an unconstitutional burden on the company. The Court held that the tax was not necessary to fund public improvements and that it was an unconstitutional burden on the company. The Court also held that the state had not provided sufficient evidence to show that the tax was necessary to fund public improvements. The Court's decision was a victory for the railway company, as it allowed the company to avoid paying the unconstitutional tax. The decision also established a precedent that states must provide sufficient evidence to show that a tax is necessary to fund public improvements before imposing it on a company.

In the case of Chicago, Milwaukee and St. Paul Railway Company v. Minnesota, Justice Harlan delivered a dissenting opinion in which he argued that the state of Minnesota had no right to impose taxes on railway companies operating within its borders without first compensating them for any losses they may incur due to such taxation. He argued that this was an unconstitutional taking of property without just compensation as it violated the Fifth Amendment’s Takings Clause which states “nor shall private property be taken for public use, without just compensation”. Furthermore, he noted that while there is some precedent allowing states to tax businesses operating within their boundaries so long as those taxes are reasonable and nondiscriminatory; however in this particular instance the tax imposed by Minnesota was neither reasonable nor non-discriminatory since it would have resulted in significant financial losses for railway companies operating within its borders with no corresponding benefit or gain provided by said state government. As such, Justice Harlan concluded his dissent by arguing against upholding the lower court ruling and instead advocated for reversing it so as to protect both individual rights under law and ensure fair treatment from all levels of government towards citizens regardless of economic status or profession