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In Northern Pacific Railroad Company v. Traill County, the Supreme Court of the United States was asked to decide whether a county in North Dakota had the authority to tax the Northern Pacific Railroad Company. The railroad company argued that the tax was unconstitutional because it violated the Commerce Clause of the United States Constitution. The Court held that the tax was unconstitutional because it interfered with interstate commerce. The Court reasoned that the tax was discriminatory because it only applied to the railroad company and not to other businesses. Furthermore, the Court held that the tax was an undue burden on interstate commerce because it imposed a greater burden on the railroad company than on other businesses. The Court concluded that the tax was unconstitutional and that the county did not have the authority to impose it.
In Northern Pacific Railroad Company v. Traill County, the Supreme Court was asked to decide whether a county in North Dakota had the authority to tax land owned by a railroad company that was granted federal lands under an act of Congress. The majority opinion held that the county did not have such authority because it would be contrary to congressional intent and could interfere with interstate commerce. However, Justice Field dissented from this decision on two grounds: first, he argued that there is no indication in either the language or legislative history of Congress' intent regarding taxation; second, he noted that if states are allowed to impose taxes on federally-granted lands then they should also be able to do so for privately-owned property as well. He concluded by stating his belief that state governments should have broad powers when it comes to taxation and regulation within their borders unless specifically prohibited by Congress or otherwise unconstitutional.