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 imposed on the railroad company for the privilege of operating within the state, and not on the goods or passengers that the railroad company transported. The Court reasoned that the tax was not a burden on interstate commerce, and thus did not violate the Commerce Clause. The Court also held that the tax was not a violation of the Due Process Clause of the Fourteenth Amendment, because the tax was imposed on the railroad company for the privilege of operating within the state, and not on the goods or passengers that the railroad company transported. The Court concluded that the tax was constitutional, and that the state had the right to impose it on the railroad company.

In Railroad Company v. Commissioners, the Supreme Court was asked to decide whether a state could impose taxes on railroad companies for their property within its borders. The majority opinion held that states have the right to tax railroads in this manner and that such taxation does not violate any constitutional rights of the company or its shareholders. Justice Field dissented from this decision, arguing that it violated both due process and equal protection clauses of the Fourteenth Amendment as well as other provisions of federal law which protect interstate commerce from undue interference by individual states. He argued further that allowing each state to impose different taxes on railroads would create an unfair burden on those companies operating across multiple jurisdictions, thus impeding interstate commerce rather than promoting it.