In the case of Postal Telegraph Cable Company v. Adams in 1894, the U.S Supreme Court ruled that a state could impose taxes on telegraph companies operating within its borders. The Mississippi-based company argued that it was exempt from taxation because it operated under federal law and across state lines. However, the court disagreed with this argument stating that while interstate commerce cannot be taxed by states, properties used for such commerce can be subjected to usual property taxations without interfering with their operations or violating constitutional provisions. Therefore, even though telegraph companies were involved in interstate communication (which is federally regulated), they were not immune to local property taxes imposed by individual states where their physical assets are located.

In the dissenting opinion for the case of Postal Telegraph Cable Company v. Adams, Justice Brewer argued that a telegraph company should not be considered as a common carrier in Mississippi. He contended that while it is true that telegraph companies perform functions similar to those of railroads and other common carriers, they are fundamentally different because their services do not involve physical transportation or movement of goods or persons from one place to another. Therefore, he believed that applying laws intended for common carriers to telegraph companies was inappropriate and unjustified. Furthermore, he expressed concern over the potential implications this ruling could have on future cases involving businesses providing communication services but not physically transporting anything.