In the case of City of New York v. New York, New Haven & Hartford Railroad Co., 1952, the Supreme Court ruled in favor of the railroad company. The city had attempted to impose property taxes on a portion of land owned by the railroad that was submerged under water and used for docking purposes. However, it was determined that this particular piece of land fell under maritime jurisdiction as per federal law and thus could not be subjected to local or state taxation laws. This ruling upheld previous decisions which stated that states cannot interfere with interstate commerce through taxation or regulation unless explicitly granted permission by Congress.

In the dissenting opinion for City of New York v. New York, New Haven & Hartford Railroad Co., it was argued that the majority had misinterpreted and misapplied principles of constitutional law in relation to taxation. The dissenters believed that the city's tax on railroad property should not be considered discriminatory or unconstitutional simply because other types of property were taxed at a lower rate. They pointed out that different types of properties have always been subject to varying rates under local tax laws, reflecting their differing uses and values. Therefore, they contended that there was no valid reason why railroads should be exempt from this common practice. Furthermore, they disagreed with the majority's view that interstate commerce was being unfairly burdened by such taxes; instead, they saw these as legitimate charges for services provided by local governments which benefited businesses including railroads.