The Northern Central Railway Company v. Maryland case in 1902 revolved around the issue of taxation on railroad franchises by states. The State of Maryland imposed a tax on the franchise of the Northern Central Railway Company, which was incorporated under Pennsylvania law but operated extensively within Maryland. The railway company challenged this tax, arguing that it violated both their charter and the U.S Constitution's commerce clause as an undue burden on interstate commerce. However, the Supreme Court ruled against them. It held that while states cannot interfere with interstate commerce directly through regulation or taxation, they can impose taxes upon corporations doing business within their borders even if such businesses are involved in interstate commerce - provided these taxes do not discriminate against or place direct burdens upon such commerce. In essence, this ruling affirmed state rights to levy non-discriminatory taxes on out-of-state companies operating within their jurisdiction without violating constitutional protections for interstate trade.

In the dissenting opinion for Northern Central Railway Company v. Maryland, Justice Harlan argued that the state of Maryland had a right to tax railroad companies operating within its borders. He contended that railroads were not exempt from taxation simply because they engaged in interstate commerce and pointed out that other businesses involved in such commerce were subject to state taxes. Harlan believed it was unjust for railroads to benefit from public services funded by taxpayers without contributing their fair share. Furthermore, he asserted that allowing states to tax these corporations did not interfere with Congress's power over interstate commerce as long as the taxes weren't discriminatory or prohibitive. In his view, this case represented an unwarranted expansion of federal authority at the expense of states' rights.