In Pickard v. Pullman Southern Car Company, the Supreme Court of the United States was asked to decide whether a state tax imposed on a railroad company was constitutional. The Pullman Southern Car Company had been assessed a tax by the state of Georgia for the privilege of operating a railroad in the state. The company argued that the tax was unconstitutional because it violated the Commerce Clause of the United States Constitution. The Supreme Court held that the tax was constitutional. The Court reasoned that the tax was not a burden on interstate commerce, but rather a legitimate exercise of the state's power to tax. The Court noted that the tax was imposed on the company's property within the state, and not on the company's activities in interstate commerce. The Court also noted that the tax was not discriminatory, and that it was imposed on all railroads operating in the state. The Court concluded that the tax was a valid exercise of the state's power to tax, and that it did not violate the Commerce Clause of the United States Constitution. The Court's decision in this case established the principle that states may impose taxes on businesses operating within their borders, even if those businesses are engaged in interstate commerce.

In Pickard v. Pullman Southern Car Company, the Supreme Court was asked to decide whether a state tax imposed on railroad companies violated the federal Constitution. The majority opinion held that it did not violate the Constitution because Congress had given states broad authority to impose taxes on railroads operating within their borders. However, Justice Field dissented from this opinion and argued that such a tax was unconstitutional because it interfered with interstate commerce in violation of Article I, Section 8 of the United States Constitution which grants Congress exclusive power over interstate commerce. He further argued that allowing states to impose taxes on railroads would lead to an increase in taxation and regulation by multiple governments which could ultimately impede or even prevent interstate trade altogether.