The U.S. Supreme Court case Powers v. Detroit, Grand Haven and Milwaukee Railway Company in 1905 revolved around a dispute over taxation of railway property in the state of Michigan. The Auditor General of Michigan, Mr. Powers, sought to collect taxes from the railway company based on an assessment that included its rolling stock (movable assets like locomotives or carriages). However, the railway company argued that this was unconstitutional as it violated their right to equal protection under law since other personal properties were not taxed similarly within the state. The court ruled in favor of the railway company stating that while states have broad powers for taxation purposes, they cannot violate constitutional protections such as equal protection clause by imposing discriminatory tax practices.

In the dissenting opinion for Powers v. Detroit, Grand Haven and Milwaukee Railway Company, it was argued that the majority's decision to uphold a Michigan law taxing railway companies based on their gross receipts violated both the Due Process Clause of the Fourteenth Amendment and principles of interstate commerce. The dissent contended that this tax unfairly burdened out-of-state businesses by forcing them to pay more than their fair share in taxes compared to local businesses. It also suggested that such taxation could lead to retaliatory measures from other states, thereby disrupting interstate commerce. Furthermore, they believed that this form of taxation did not provide sufficient notice or opportunity for hearing before being imposed which is contrary to due process rights under Fourteenth Amendment.