In District of Columbia Commissioners v. Baltimore & Potomac Railroad Company, the Supreme Court was asked to decide whether the District of Columbia Commissioners had the authority to regulate the speed of trains in the District. The Commissioners had issued an order limiting the speed of trains to 12 miles per hour in the city, and the Railroad Company had challenged the order, arguing that the Commissioners did not have the authority to regulate the speed of trains. The Supreme Court held that the Commissioners did have the authority to regulate the speed of trains in the District. The Court reasoned that the Commissioners had the power to regulate the speed of trains in order to protect the safety of the public, and that the order was a reasonable exercise of that power. The Court also noted that the Railroad Company had not shown that the order was unreasonable or that it would cause them any undue hardship. The Court thus affirmed the order of the Commissioners, holding that they had the authority to regulate the speed of trains in the District of Columbia.

In the case of District of Columbia Commissioners v. Baltimore & Potomac Railroad Company, Justice Field delivered a dissenting opinion in which he argued that the majority had misconstrued the meaning and intent of Congress when it passed an act to incorporate the railroad company. He believed that Congress intended for all property owned by or leased to the corporation, including its franchises and rights-of-way, to be exempt from taxation by any state or municipal authority. This was consistent with other acts passed at around this time granting similar exemptions for corporations operating within Washington D.C., as well as those incorporated under federal law elsewhere in America. Furthermore, Justice Field contended that if such taxes were allowed then they would constitute a burden on interstate commerce and thus violate Article I Section 8 Clause 3 of The Constitution which grants exclusive power over interstate commerce exclusively to Congress.