The case of Ohio River and Western Railway Company v. Dittey et al., as the Tax Commission of Ohio, in 1913 revolved around a dispute over taxation. The railway company argued that the tax commission's method for assessing property taxes was unfair and unconstitutional because it did not consider the actual value of their properties but rather used an arbitrary percentage based on total capital stock to determine taxable values. This resulted in higher assessed values than what they believed were accurate, leading to excessive taxation. However, the Supreme Court ruled against them stating that while there may be errors or inequalities in assessment methods, these do not necessarily make them unconstitutional unless they are intentionally discriminatory or violate due process rights under Fourteenth Amendment protections. Therefore, despite potential inaccuracies with valuation methods employed by state tax commissions at times, such practices could still fall within constitutional bounds provided no intentional discrimination is involved.

In the dissenting opinion for Ohio Tax Cases; Ohio River and Western Railway Company v. Dittey et al., as The Tax Commission of Ohio, 1913, it was argued that the court majority erred in its interpretation of due process rights under the Fourteenth Amendment. The dissenters believed that there was no violation of these rights by the state tax commission's assessment methods. They contended that a state has broad powers to determine how property within its jurisdiction is assessed for taxation purposes and this power should not be interfered with unless clear violations are evident. Furthermore, they disagreed with the majority's view on what constitutes fair market value in terms of railroad properties' assessments, arguing instead for a more flexible approach which takes into account various factors such as earning capacity or potential income from use rather than just physical assets alone.