The U.S. Supreme Court case Kansas City, Fort Scott & Memphis Railway Company v. Botkin, Secretary of State of the State of Kansas in 1915 revolved around a dispute over taxation and corporate rights. The railway company argued that it was being unfairly taxed by the state due to an alleged violation of its charter's terms, which had been granted by the state legislature but later amended without their consent. They claimed this amendment violated their Fourteenth Amendment rights under the U.S Constitution as it deprived them of property without due process and denied them equal protection under law. However, the court ruled against them stating that corporations are creations of state law and thus subject to changes made by those states' legislatures unless specifically protected from such changes within their charters or contracts with said states.

In the dissenting opinion for Kansas City, Fort Scott & Memphis Railway Company v. Botkin, it was argued that the state of Kansas did not have jurisdiction to tax property located outside its borders. The justice contended that a railway company's rolling stock (locomotives and cars), even if used in part within Kansas, should not be subject to taxation by the state when they are also used extensively beyond its boundaries. He maintained that such an imposition would violate principles of interstate commerce and due process under federal law. Furthermore, he suggested this could lead to multiple states attempting to tax the same property based on usage within their respective jurisdictions - resulting in excessive taxation which is unfair and unconstitutional.