The U.S. Supreme Court case Missouri Pacific Railroad Company et al. v. Western Crawford Road Improvement District in 1924 revolved around the issue of taxation and public improvements, specifically whether a railroad company could be taxed for road improvements that did not directly benefit it. The Western Crawford Road Improvement District in Arkansas levied an assessment on the Missouri Pacific Railroad Company to fund local road upgrades, arguing that all property owners within the district should contribute to such projects regardless of direct benefits received from them. However, the railroad company argued this was unfair as they derived no advantage from these particular improvements and thus shouldn't have to pay taxes for them. The Supreme Court ruled in favor of the railroad company stating that while general taxation is permissible even if there's no direct benefit to a taxpayer, special assessments (like those levied by improvement districts) must show some special benefit conferred upon properties assessed beyond what is enjoyed by other properties or citizens generally before they can be justified constitutionally.

In the dissenting opinion for Missouri Pacific Railroad Company et al. v. Western Crawford Road Improvement District, Justice Holmes argued that the majority's decision was inconsistent with previous rulings of the Court and violated principles of federalism by allowing a state to impose its own tax system on interstate commerce without regard for how it might affect other states or conflict with national policy. He believed that while states have broad powers to regulate local matters, they should not be allowed to interfere in areas where Congress has exclusive authority such as interstate commerce. The imposition of taxes on railroads operating across state lines is one such area because it could potentially lead to multiple taxation and create barriers to free trade among states which would undermine national unity and economic efficiency. Therefore, he concluded that the Arkansas law at issue in this case was unconstitutional because it imposed an undue burden on interstate commerce contrary to the Commerce Clause of U.S Constitution.