In City of St. Louis v. United States, the Supreme Court was asked to decide whether the City of St. Louis had the right to tax the United States for the use of its property. The City of St. Louis had imposed a tax on the United States for the use of its property, which the United States argued was unconstitutional. The Supreme Court held that the City of St. Louis did not have the right to tax the United States for the use of its property. The Court reasoned that the United States was immune from taxation by the states, and that the City of St. Louis was a part of the state of Missouri. Therefore, the City of St. Louis did not have the right to tax the United States for the use of its property. The Court also held that the City of St. Louis could not tax the United States for the use of its property, even if the tax was for a public purpose. The Court reasoned that the United States was immune from taxation by the states, and that the City of St. Louis was a part of the state of Missouri. Therefore, the City of St. Louis did not have the right to tax the United States for the use of its property.

Justice Field delivered the dissenting opinion in City of St. Louis v. United States, arguing that Congress had no authority to pass a law regulating commerce between states and foreign nations or among the several states. He argued that this power was reserved for the individual states under the Tenth Amendment, which reads: "The powers not delegated to the United States by the Constitution, nor prohibited by it to the States, are reserved to the States respectively, or to people." Justice Field further argued that if Congress were allowed such broad powers over interstate commerce then it could interfere with state laws regarding taxation and other matters related thereto. In conclusion he stated that allowing Congress such expansive authority would be detrimental both economically and politically as it would give too much control over local affairs into federal hands at detriment of citizens' rights protected by their respective state constitutions.