The U.S. Supreme Court case Kansas City Southern Railway Company et al. v. Road Improvement District No 3 of Sevier County, Arkansas, et al., in 1924 revolved around the issue of taxation and its impact on interstate commerce. The Kansas City Southern Railway Company challenged a tax imposed by the Road Improvement District No 3 of Sevier County, Arkansas for road improvements near their railway lines arguing that it violated the Commerce Clause as it interfered with interstate commerce by imposing an undue burden on them. However, the court ruled against this argument stating that such taxes were not discriminatory or excessive and did not pose a direct burden on interstate commerce but rather served to facilitate it through infrastructure improvement which was beneficial to all including businesses like railways involved in interstate trade.

In the dissenting opinion for Kansas City Southern Railway Company v. Road Improvement District No 3 of Sevier County, Arkansas, Justice McReynolds argued that the majority's decision to uphold a tax assessment against the railway company was unjust and inconsistent with previous rulings. He contended that it was unfair to impose such a heavy burden on railroads when other forms of property were not similarly taxed. The justice also pointed out inconsistencies in how different states treated railroad properties for taxation purposes, which he believed violated principles of equal protection under law. Furthermore, he expressed concern about potential negative impacts on interstate commerce due to excessive state taxation on railroads. In his view, this case represented an overreach by local authorities at the expense of federal interests and constitutional rights.