In the case of Illinois Grand Trunk Railway Company v. Wade in 1890, the U.S. Supreme Court ruled on a dispute involving railway property taxes. The Illinois Grand Trunk Railway Company had been assessed for personal property tax by Cook County, Illinois but refused to pay it arguing that its rolling stock was not located within the county long enough to be considered taxable property there. However, both lower courts sided with Cook County and held that such transient presence did not exempt them from taxation as they were regularly conducting business in the area. The Supreme Court affirmed these rulings stating that if a corporation conducts regular business operations within a state or county, then it is liable for local taxation even if its physical assets are only temporarily present there. This decision established an important precedent regarding corporate tax liability and jurisdictional boundaries.

In the dissenting opinion for Illinois Grand Trunk Railway Company v. Wade, it was argued that the majority's decision to hold a railway company liable for damages caused by sparks from its locomotives was unjustified. The dissenting justices believed that such an occurrence should be considered as an inevitable accident rather than negligence on part of the railway company. They contended that holding companies responsible in this manner would set a dangerous precedent and could potentially cripple industries vital to national growth and development. Furthermore, they pointed out inconsistencies in how similar cases had been handled previously, arguing for more uniformity in legal decisions regarding industrial accidents.