In the case of Emigrant Company v. County of Adams, the Supreme Court of the United States was asked to decide whether a county could tax a company for the privilege of doing business within its borders. The Emigrant Company was a corporation that operated a ferry across the Mississippi River. The County of Adams had imposed a tax on the company for the privilege of operating the ferry. The company argued that the tax was unconstitutional because it was a direct tax on the company's property, which was prohibited by the Constitution. The Supreme Court held that the tax was not a direct tax on the company's property, but rather a tax on the privilege of doing business within the county. The Court reasoned that the tax was not a direct tax on the company's property because it was not imposed on the property itself, but rather on the company's right to do business within the county. The Court also noted that the tax was not a tax on the company's income, but rather a tax on the privilege of doing business within the county. The Court concluded that the tax was constitutional and that the county had the right to impose it. The Court noted that the tax was not excessive and that it was not an undue burden on the company. The Court also noted that the tax was not discriminatory and that it was applied equally to all businesses operating within the county. The Court held that the tax was a valid exercise of the county's power to tax and that the company was liable for the tax.

In the case of Emigrant Company v. County of Adams, the Supreme Court was asked to decide whether a county could tax an emigration company for its business operations within that county. The majority opinion held that such taxation was unconstitutional because it violated the Commerce Clause and impeded interstate commerce. However, Justice Field dissented from this decision on two grounds: firstly, he argued that Congress had not yet enacted legislation prohibiting states from taxing businesses engaged in interstate commerce; secondly, he maintained that even if Congress had done so, there were no facts presented which showed any actual impediment to interstate commerce caused by the taxation at issue here. He concluded by stating his belief that "the power of taxation is one belonging exclusively to each State" and should be exercised accordingly unless prohibited by some act of Congress or provision in the Constitution itself.