The U.S. Supreme Court case Groesbeck et al. v. Duluth, South Shore & Atlantic Railway Company in 1919 revolved around a dispute over taxation of railway properties in the state of Michigan. The plaintiffs, tax officials from Michigan, argued that the defendant (the railway company) had not paid enough taxes on its property within the state's borders and sought to collect additional amounts based on their assessment of value for those properties. However, the railway company contended that it was already taxed fairly according to federal law which stipulated uniformity in taxing interstate commerce entities such as themselves and any further taxation would be discriminatory and unconstitutional under both due process clause and equal protection clause of Fourteenth Amendment. The Supreme Court sided with the railroad company ruling that states could not impose higher or additional taxes on out-of-state companies than they did on similar businesses operating solely within their boundaries because this violated principles of fairness embedded in constitutional provisions mentioned above.

In the dissenting opinion for Groesbeck et al. v. Duluth, South Shore & Atlantic Railway Company, Justice Holmes disagreed with the majority's decision to uphold a Michigan law that required railroads to maintain and operate certain branch lines even if they were unprofitable. He argued that this requirement was an unconstitutional taking of property without just compensation under the Fifth Amendment because it forced companies to use their resources in ways that might not be economically viable or beneficial for them. Furthermore, he contended that while states have broad powers over local matters such as public utilities regulation, these powers should not extend so far as to infringe upon private property rights protected by the Constitution.