The U.S. Supreme Court case New York Central & Hudson River Railroad Company v. Board of Chosen Freeholders of the County of Hudson in 1912 revolved around a dispute over taxation and property rights. The railroad company contested that it was unjustly taxed by the county for its ferryboats, which were used to transport passengers across bodies of water along their routes, arguing these should be considered as part of their rail system and thus exempt from local taxation under New Jersey law. However, the court ruled against them stating that while they may serve an integral function in transporting passengers on behalf of the railway company, ferryboats are not technically rails or tracks themselves and therefore do not qualify for this exemption. This decision upheld previous rulings made at both district and state levels affirming that such vessels can indeed be subject to local taxes separate from those imposed on actual railway infrastructure.

In the dissenting opinion for New York Central & Hudson River Railroad Company v. Board of Chosen Freeholders of the County of Hudson, it was argued that the majority's decision to uphold a tax imposed by New Jersey on railroad property in its state violated constitutional principles. The dissenters contended that this ruling allowed states to impose taxes on interstate commerce, which they believed was contrary to the Commerce Clause of the U.S Constitution. They also disagreed with how property value assessments were made and felt these did not accurately reflect market values or consider depreciation over time. Furthermore, they expressed concern about potential discrimination against out-of-state businesses if each state could levy such taxes independently without federal oversight or uniformity in assessment methods.