The U.S. Supreme Court case Michigan v. Flint and Pere Marquette Railroad Company in 1893 revolved around a dispute over taxation of railroad properties by the state of Michigan. The Flint and Pere Marquette Railroad Company challenged the tax, arguing that it was unconstitutional because it violated an agreement made when the company was incorporated which exempted its property from further taxation beyond what had been initially agreed upon. However, this exemption had not been explicitly stated in their charter but rather inferred from other documents related to their incorporation process. The Supreme Court ruled against the railroad company, stating that any such exemptions must be clearly expressed within a corporation's charter as per previous legal precedent (Dartmouth College v Woodward). Therefore, since no explicit exemption existed within their charter, they were subject to additional taxes imposed by Michigan law. This decision reinforced states' rights to impose taxes on corporations unless specifically prohibited by clear language in corporate charters or constitutions.

The dissenting opinion in the case of Michigan v. Flint and Pere Marquette Railroad Company argued that the state had a right to tax railroad companies for their property, including rolling stock. The justice disagreed with the majority's interpretation of "commerce" under the Commerce Clause, arguing that it should not be so broadly defined as to include all activities related to transportation by railroads. They believed this broad definition infringed upon states' rights to regulate and tax businesses within their borders. Furthermore, they contended that if every activity remotely connected with commerce was protected from state taxation or regulation under the Commerce Clause, then virtually no business could be taxed or regulated by states at all - an outcome they deemed absurd and contrary to established principles of federalism.