The U.S. Supreme Court case Great Northern Railway Company v. Minnesota in 1928 revolved around the issue of whether a state could impose an ad valorem tax on railroad companies for their intangible personal property, such as franchises and rights-of-way. The Great Northern Railway Company argued that this taxation was unconstitutional because it violated the Due Process Clause of the Fourteenth Amendment by taxing property outside its jurisdiction and also infringed upon interstate commerce regulations. However, the court ruled against them with Justice Oliver Wendell Holmes delivering the opinion of a unanimous court stating that these taxes were not discriminatory or arbitrary but rather represented just compensation for public services provided by railroads within Minnesota's borders.

In the dissenting opinion for Great Northern Railway Company v. Minnesota, Justice Stone argued that the state of Minnesota had a right to regulate and tax railroad companies operating within its borders. He disagreed with the majority's interpretation of federal law as preempting state authority in this area. According to him, states should have broad power to manage their own affairs without undue interference from federal authorities or courts. He also pointed out that railroads are not merely private businesses but public utilities providing essential services; therefore they should be subject to more stringent regulation and taxation than ordinary commercial enterprises. Furthermore, he contended that allowing states greater leeway in dealing with railroads would promote competition and prevent monopolistic practices detrimental to consumers' interests.