The U.S. Supreme Court case Columbus & Greenville Railway Company et al. v. Miller, State Tax Collector, for the Use of the Mississippi Levee District in 1930 revolved around a dispute over taxation rights on interstate commerce and property within state borders. The Columbus & Greenville Railway Company argued that it was unconstitutional for their railway bridges to be taxed by Mississippi as they were part of an interstate commerce system and thus should fall under federal jurisdiction according to the Commerce Clause of the Constitution. However, Mississippi countered this argument stating that while railways are indeed used for interstate commerce, they also exist physically within state boundaries making them subject to local tax laws too. The Supreme Court ruled in favor of Miller (Mississippi), holding that states have a right to tax property located within their borders even if it is used as part of an interstate commercial operation such as railroads or bridges associated with these operations.

In the dissenting opinion for Columbus & Greenville Railway Company et al. v. Miller, State Tax Collector, for the Use of The Mississippi Levee District, Justice Holmes argued that the tax imposed by Mississippi on railroads was not discriminatory and did not violate the Commerce Clause of the U.S Constitution as claimed by majority justices. He contended that all businesses in a state are subject to taxation under its laws regardless of whether they engage in interstate commerce or not. According to him, it is only when a state law imposes an undue burden on interstate commerce or discriminates against it unfairly compared with local business does it become unconstitutional under Commerce Clause jurisprudence. In this case however, he believed there was no evidence showing such discrimination or undue burden caused by Mississippi's tax law on railroads engaging in both intrastate and interstate commerce.