In the case of State of Oklahoma v. Atchison, Topeka and Santa Fe Railway Company in 1910, the Supreme Court ruled on a dispute between a state government and a railway company regarding taxation. The State of Oklahoma had imposed an annual tax on railroads operating within its borders based on their gross earnings from both interstate and intrastate commerce. The Atchison, Topeka & Santa Fe Railway Company challenged this tax as unconstitutional under the Commerce Clause which prohibits states from interfering with interstate commerce. The Supreme Court sided with the railway company stating that while states have power to tax businesses operating within their boundaries, they cannot impose taxes that discriminate against or burden interstate commerce. Therefore, it was held that taxing gross earnings derived from both sources (interstate and intrastate) without making any distinction is indeed discriminatory towards interstate commerce thus violating the Commerce Clause.

In the dissenting opinion for the case of State of Oklahoma v. Atchison, Topeka and Santa Fe Railway Company, it was argued that the Supreme Court should not have interfered with Oklahoma's decision to regulate railway rates within its own borders. The dissenting justices believed that states should have autonomy in such matters unless there is a clear violation of federal law or constitutional rights. They contended that this interference by the court undermined state sovereignty and disrupted balance between federal and state powers as intended by constitution framers. Furthermore, they disagreed with majority’s view on due process clause application; arguing instead that lower rates did not necessarily equate to confiscation without due process under Fourteenth Amendment - an issue central to this case. In their view, whether these regulated rates allowed railroads reasonable returns (thus avoiding confiscation) was a question better left for local authorities who were more familiar with specific circumstances than distant federal judges.