In the case of Chicago, Milwaukee and St. Paul Railroad Company v. State of Wisconsin in 1914, the Supreme Court ruled on a dispute regarding taxation between a railroad company and the state government. The railroad company argued that its property was unfairly assessed for tax purposes at full value while other properties were not, violating equal protection under law as per Fourteenth Amendment to US Constitution. However, the court upheld Wisconsin's right to tax railroads differently from other types of property due to their unique nature and importance within society. It found no violation of Equal Protection Clause because it held that uniformity in taxation wasn't necessary if there was reasonable basis for different treatment; here being difference between tangible and intangible properties or personal versus corporate ownerships etc., which could be legitimately considered by states when setting up their taxing schemes.

In the dissenting opinion for the case of Chicago, Milwaukee and St. Paul Railroad Company v. State of Wisconsin, Justice Holmes argued that while it is within a state's power to regulate rates charged by railroads operating within its borders, this power should not be used arbitrarily or in a manner that would harm interstate commerce. He believed that the majority decision was an overreach of state authority and could potentially lead to unjust outcomes if other states followed suit. Furthermore, he contended that such regulation should only be applied when there is clear evidence of abuse on part of the railroad companies which was lacking in this case according to him. Therefore, he disagreed with his colleagues' ruling upholding Wisconsin's right to set maximum freight rates for intrastate shipments on grounds they were reasonable and did not interfere with interstate commerce.