In Railroad Company v. Commissioners, the Supreme Court of the United States was asked to decide whether a state could impose a tax on a railroad company for the privilege of operating within its borders. The railroad company argued that the tax was unconstitutional because it violated the Commerce Clause of the United States Constitution. The Court held that the tax was constitutional because it was a valid exercise of the state's power to tax and regulate businesses within its borders. The Court also held that the tax did not violate the Commerce Clause because it was not a direct burden on interstate commerce. The Court reasoned that the tax was a valid exercise of the state's power to tax and regulate businesses within its borders, and that it did not discriminate against interstate commerce. The Court concluded that the tax was a valid exercise of the state's power to tax and regulate businesses within its borders, and that it did not violate the Commerce Clause.

In Railroad Company v. Commissioners, the Supreme Court was tasked with determining whether a state law that imposed a tax on railroad companies violated the Constitution's Contract Clause. The majority opinion held that it did not violate the clause because it applied to all railroads in equal measure and thus did not impair any existing contracts between them and their customers or creditors. Justice Field dissented from this decision, arguing that while the law may have been intended to apply equally across all railroads, its effect was unequal as some of them had already entered into contracts prior to its enactment which provided for different rates than those set by the new statute. He further argued that these preexisting contractual rights should be respected even if they are disadvantageous to one party over another since such arrangements were made freely at an earlier time when both parties knew what terms would apply under each agreement.