In the 1913 case Harrison, Secretary of State of Oklahoma v. St. Louis & San Francisco Railroad Company, the Supreme Court ruled in favor of the railroad company. The state of Oklahoma had passed a law requiring all corporations to pay an annual tax based on their capital stock and surplus funds; failure to do so would result in forfeiture of corporate rights and privileges within the state. The St. Louis & San Francisco Railroad Company refused to pay this tax, arguing that it was unconstitutional as it violated both due process under the Fourteenth Amendment and interstate commerce regulations by taxing property outside Oklahoma's jurisdiction (the railroad operated across multiple states). The Supreme Court agreed with these arguments, holding that while states have power over domestic corporations within their borders, they cannot impose taxes on out-of-state properties or operations belonging to those corporations.

In the dissenting opinion for Harrison v. St. Louis & San Francisco Railroad Company, it was argued that the Oklahoma state law requiring railroads to maintain and operate stations in certain towns did not violate the Fourteenth Amendment's due process clause. The dissenting justices believed that states should have regulatory power over businesses operating within their borders, especially when public welfare is at stake. They contended that this regulation was a reasonable exercise of police power aimed at ensuring public convenience and safety rather than an arbitrary or unjustifiable interference with private business operations. Furthermore, they disagreed with the majority's view on 'due process,' arguing instead that it does not prevent states from adjusting rights and responsibilities as required by changing circumstances or collective needs of society.