The U.S. Supreme Court case Choctaw, Oklahoma & Gulf Railroad Company v. Harrison, Sheriff of Pittsburg County, Oklahom in 1914 revolved around the issue of taxation on railroad companies operating within Indian Territory (now part of Oklahoma). The Choctaw, Oklahoma & Gulf Railroad Company argued that they were exempt from state taxation due to a federal statute which granted them certain rights and privileges when their railway was constructed through Indian Territory. However, the State of Oklahoma contended that upon its admission into the Union in 1907 it gained authority over all lands within its borders including those previously designated as Indian Territory. The Supreme Court ruled in favor of the State of Oklahoma stating that once admitted to the Union under equal footing doctrine with other states; it had full jurisdictional powers for tax purposes over all property located within its boundaries regardless any previous federal statutes or agreements made prior to statehood.

In the dissenting opinion for Choctaw, Oklahoma & Gulf Railroad Company v. Harrison, Sheriff of Pittsburg County, Oklahom (1914), Justice Holmes disagreed with the majority's ruling that a state tax on railroad companies was unconstitutional because it violated the Commerce Clause. He argued that states should have more power to regulate and tax businesses within their borders without interference from federal law or courts. He believed this case represented an overreach by the Supreme Court into matters better left to individual states' discretion and control. Furthermore, he contended that such taxes did not necessarily burden interstate commerce as long as they were applied fairly across all similar types of businesses in a given state.