In Railroad Company v. Georgia, the Supreme Court of the United States was asked to decide whether a state could impose a tax on a railroad company that was 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 discriminatory against interstate commerce. The Court reasoned that the tax was applied equally to all businesses operating within the state, regardless of whether they were engaged in interstate commerce or not. The Court also noted that the tax was not excessive and did not place an undue burden on interstate commerce. As such, the Court held that the tax was constitutional and did not violate the Commerce Clause.

Justice Field delivered the dissenting opinion in Railroad Company v. Georgia, arguing that the state of Georgia had violated the Fourteenth Amendment by enacting a law that imposed an unconstitutional burden on interstate commerce. He argued that while states have broad powers to regulate their own internal affairs, they cannot interfere with or impede interstate commerce without violating constitutional protections for such activities. Furthermore, he noted that this particular law was particularly egregious because it singled out railroad companies and imposed a special tax upon them which other businesses were not required to pay. In conclusion, Justice Field asserted that if allowed to stand, this decision would set a dangerous precedent whereby states could impose arbitrary taxes and regulations on any form of interstate commerce at will - something which is clearly prohibited under both federal and state constitutions alike.