In Railroad Company v. Mississippi, the Supreme Court of the United States was asked to decide whether a state could tax a railroad company's property located 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 property within its borders. The Court noted that the tax was not discriminatory and did not interfere with interstate commerce. The Court also noted that the tax was not excessive and did not place an undue burden on the railroad company. The Court concluded that the tax was a valid exercise of the state's power to tax property within its borders and was not unconstitutional.

Justice Field delivered the dissenting opinion in Railroad Company v. Mississippi, arguing that the state of Mississippi had no right to tax a railroad company on its bonds and stocks owned by citizens of other states. He argued that this was an unconstitutional interference with interstate commerce because it would impose a burden on those who own such securities from outside the state. Furthermore, he contended that if each state were allowed to tax these securities then it could lead to double taxation or unequal treatment among different states which would be detrimental for interstate commerce as well as investors from out-of-state. Justice Field concluded his dissent by stating that Congress should have exclusive power over regulating interstate commerce and not individual states since any action taken at a local level can have far reaching consequences across multiple jurisdictions.