In OLCOTT v. THE SUPERVISORS, the Supreme Court of the United States was asked to decide whether a state law that allowed the supervisors of a county to levy a tax on the property of a railroad company was constitutional. The railroad company argued that the tax was unconstitutional because it violated the Fourteenth Amendment's Equal Protection Clause. The Supreme Court held that the tax was constitutional. The Court reasoned that the Fourteenth Amendment did not prohibit a state from taxing the property of a railroad company, as long as the tax was applied equally to all property owners in the state. The Court also noted that the tax was not discriminatory, as it was applied to all property owners in the county, regardless of whether they owned a railroad or not. The Court concluded that the tax was constitutional and that the supervisors of the county had the authority to levy it. This decision established that the Fourteenth Amendment did not prohibit states from taxing the property of railroad companies, as long as the tax was applied equally to all property owners in the state.

In OLCOTT v. THE SUPERVISORS, the Supreme Court was asked to decide whether a state law that allowed for the taxation of property held by religious organizations violated the First Amendment's Free Exercise Clause. The majority opinion found that it did not violate this clause and upheld the law in question. However, Justice Field dissented from this decision and argued that such a tax would be unconstitutional because it interfered with an individual’s right to freely exercise their religion without government interference or regulation. He further stated that any attempt by government to interfere with religious practice should only be done when absolutely necessary and even then must be done in as limited manner as possible so as not to infringe upon individuals' rights under the Constitution. In his view, taxing property owned by churches was unnecessary since there were other ways for states to raise revenue without infringing on people's constitutional rights; thus he concluded that allowing such taxes violated both freedom of religion and equal protection clauses of the Fourteenth Amendment which guarantee all citizens equal treatment under law regardless of race or creed.