In the 1905 case of Michigan Central Railroad Company v. Powers, Auditor General of the State of Michigan, the U.S. Supreme Court was asked to determine whether a state law that imposed specific taxes on railroad companies violated the Constitution's Equal Protection Clause. The Michigan Central Railroad Company argued that it was being unfairly targeted by this tax and sought relief from its enforcement. However, after reviewing the matter, the Supreme Court disagreed with their claim and upheld Michigan's right to impose such a tax. The court ruled that states have broad powers when it comes to taxation as long as they do not violate any explicit constitutional prohibitions or infringe upon federal jurisdiction. In this instance, there were no discriminatory practices involved in imposing these taxes; all railroads operating within state lines were subject to them equally. Therefore, even though these taxes may have been burdensome for some companies like Michigan Central Railroad Co., they did not constitute an unfair practice under equal protection laws because every company in similar circumstances faced identical obligations.

The dissenting opinion in the case of Michigan Central Railroad Company v. Powers, Auditor General of the State of Michigan, argued that the tax imposed by Michigan on railroads was unconstitutional because it violated both due process and equal protection clauses. The justice contended that this specific tax unfairly targeted railroad companies while exempting other types of property from taxation. This selective imposition constituted a violation of equal protection under law as guaranteed by the Fourteenth Amendment. Furthermore, they believed that there was no rational basis for such discriminatory treatment against railroads which made it arbitrary and thus violating due process rights too. They also disagreed with majority's interpretation about 'just compensation' clause arguing that just because a company uses public resources (like land), doesn't mean state can impose any amount as taxes without considering fairness or reasonableness.