In Railroad Company v. County of Hamblen, the Supreme Court of the United States was asked to decide whether a county could tax a railroad company for the value of its property. The railroad company argued that the tax was unconstitutional because it violated the Fourteenth Amendment's Equal Protection Clause. The Court held that the tax was constitutional because it was based on the value of the property and not on the company's income or profits. The Court also held that the tax was not a taking of the company's property without just compensation, as the company was still able to use the property for its intended purpose. The Court concluded that the tax was a valid exercise of the county's taxing power and did not violate the Fourteenth Amendment.

In Railroad Company v. County of Hamblen, the Supreme Court was asked to decide whether a county could tax railroad companies for their property within its borders. The majority opinion held that counties had no authority to impose such taxes on railroads and thus affirmed the lower court's decision in favor of the railroad company. Justice Field dissented from this ruling, arguing that states have traditionally been able to levy taxes upon corporations operating within their boundaries and that there is nothing in either state or federal law which prevents them from doing so with respect to railroads. He further argued that allowing counties to tax railroads would not interfere with interstate commerce as long as each state imposed similar taxation schemes on all entities operating therein; therefore, he concluded, it should be permissible for a county like Hamblen County heretofore mentioned do so as well.