In the case of Mobile, Jackson and Kansas City Railroad Company v. State of Mississippi in 1907, the U.S Supreme Court ruled on a dispute concerning taxation. The state had levied taxes against the railroad company based on its property value within Mississippi's borders. However, the railroad company argued that this was unconstitutional as it violated their rights under both due process and equal protection clauses because they were being taxed for property located outside of Mississippi's jurisdiction. The court disagreed with this argument stating that states have a right to tax businesses operating within their boundaries even if part or all of their assets are located elsewhere. Therefore, it upheld Mississippi’s right to levy such taxes.

In the dissenting opinion for Mobile, Jackson and Kansas City Railroad Company v. State of Mississippi, Justice Harlan argued that the state had no right to impose taxes on a railroad company chartered by another state and operating within its borders under an interstate commerce agreement. He contended that such taxation was in violation of the Commerce Clause of the U.S Constitution which grants Congress exclusive authority over interstate commerce. Furthermore, he maintained that this case did not involve simply a question about tax rates or assessments but rather concerned whether states could interfere with federal control over interstate commerce at all. The majority's decision allowing Mississippi to tax an out-of-state corporation engaged in interstate business activities would set a dangerous precedent undermining national economic unity and potentially leading to retaliatory taxation among states.