In Memphis Gas Light Company v. Taxing District of Shelby County, the Supreme Court of the United States was asked to decide whether a state could tax a gas company for the privilege of doing business within its borders. The gas company argued that the tax was unconstitutional because it was a direct tax on the company's property, which was prohibited by the Constitution. The taxing district argued that the tax was a valid exercise of the state's power to tax businesses within its borders. The Supreme Court held that the tax was unconstitutional because it was a direct tax on the company's property. The Court reasoned that the tax was a direct tax on the company's property because it was imposed on the company's right to do business in the state. The Court also noted that the tax was not apportioned among the states, as required by the Constitution. The Court concluded that the tax was unconstitutional and that the company was not liable for the tax. This decision established the principle that a state cannot impose a direct tax on a company's property without apportioning it among the states.

Justice Field delivered the dissenting opinion in this case. He argued that the tax imposed by Shelby County was not a direct tax, but rather an excise or privilege tax which could be levied on companies operating within its jurisdiction. The majority had held that such taxes were unconstitutional because they violated the uniformity clause of Article I, Section 8 of the Constitution. Justice Field disagreed with this conclusion and asserted that it was beyond Congress' power to determine what constituted a direct or indirect tax for purposes of taxation under state law. Furthermore, he argued that even if Congress did have such authority, it would still be up to each individual state to decide whether any particular type of taxation fell into one category or another based upon their own laws and regulations. Finally, he noted that while there may have been some inequities in how different states taxed certain activities (such as gas production), these issues should be addressed through legislation rather than judicial decisions which could potentially disrupt existing economic arrangements between states and businesses operating within them.