In the case of Lehigh Valley Railroad Company v. Pennsylvania (1891), the U.S. Supreme Court was asked to determine whether a state tax on freight transported within its borders violated the Commerce Clause of the Constitution, which gives Congress exclusive power over interstate commerce. The State of Pennsylvania had imposed a tax on all freight carried by railroads operating in its territory, including goods that originated and were destined for out-of-state locations. The Lehigh Valley Railroad Company challenged this law as an unconstitutional interference with interstate commerce. The Supreme Court ruled in favor of Pennsylvania, holding that states have authority to impose taxes on businesses operating within their boundaries even if those operations include aspects of interstate commerce. The court reasoned that while regulation of such activities is reserved for Congress under the Commerce Clause, taxation does not amount to regulation and therefore falls outside federal purview unless it discriminates against or places undue burdens upon interstate trade - conditions not met in this instance according to majority opinion.

In the dissenting opinion for Lehigh Valley Railroad Company v. Pennsylvania, Justice Bradley argued that the state of Pennsylvania did not have jurisdiction to tax freight transported through multiple states. He believed that such a tax was an infringement on interstate commerce and therefore unconstitutional under the Commerce Clause of the U.S Constitution. The justice contended that while states can regulate certain aspects within their borders, they cannot interfere with or impose burdens on interstate commerce as it is exclusively regulated by Congress. Thus, he disagreed with majority's decision upholding Pennsylvania’s right to levy taxes on railroad companies based on tonnage carried across state lines.