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The Supreme Court case of Louisville, New Orleans and Texas Railway Company v. Mississippi was a dispute between the railway company and the state of Mississippi. The railway company had been granted a charter by the state of Mississippi in 1882, which allowed them to construct a railway line from the Mississippi River to the Gulf of Mexico. However, the state of Mississippi later passed a law that prohibited the railway company from constructing the line. The railway company argued that the law was unconstitutional and violated their rights under the Fourteenth Amendment. The Supreme Court ultimately ruled in favor of the railway company, finding that the law was unconstitutional and violated the railway company's rights under the Fourteenth Amendment. The Court held that the law was an unconstitutional interference with the railway company's right to contract and to engage in interstate commerce. The Court also held that the law was an unconstitutional taking of the railway company's property without just compensation. This decision established the principle that states cannot pass laws that interfere with the rights of private companies to engage in interstate commerce.
In the dissenting opinion of Louisville, New Orleans and Texas Railway Company v. Mississippi, Justice Harlan argued that the state's taxation of interstate commerce was unconstitutional under the Commerce Clause. He believed that while states have a right to tax their own citizens and businesses within their borders, they do not have authority over interstate commerce which is reserved for Congress alone. Furthermore, he noted that if each state could impose taxes on goods moving through its territory then it would create an undue burden on interstate trade as well as lead to discrimination against out-of-state companies in favor of local ones. In conclusion, Justice Harlan argued that such taxation by individual states violated both the letter and spirit of Article I Section 8 Clause 3 (the Commerce Clause) of the United States Constitution.