In the case of Railway Company v. Philadelphia, the Supreme Court of the United States was asked to decide whether a city could impose a tax on a railway company for the privilege of operating its railway within the city limits. The railway company argued that the tax was unconstitutional because it violated the Commerce Clause of the United States Constitution. The Supreme Court held that the tax was constitutional. The Court reasoned that the tax was not a burden on interstate commerce, but rather a legitimate exercise of the city's power to tax. The Court noted that the tax was imposed on the railway company for the privilege of operating within the city limits, and not on the goods or passengers that were transported. The Court also noted that the tax was not discriminatory, as it was imposed on all railway companies operating within the city limits. The Court concluded that the tax was a valid exercise of the city's power to tax, and did not violate the Commerce Clause of the United States Constitution. The Court held that the tax was constitutional, and the railway company was required to pay it.

Justice Field delivered the dissenting opinion in Railway Company v. Philadelphia, arguing that the majority's decision was inconsistent with prior Supreme Court precedent and would lead to an unjust result. He argued that the City of Philadelphia had no authority to impose a tax on property owned by a railroad company located outside its boundaries, as it had done in this case. The city claimed it could do so because of its power under Pennsylvania law; however, Justice Field noted that such laws were not applicable when they conflicted with federal legislation or constitutional rights. Furthermore, he argued that if cities were allowed to tax out-of-state property owners without their consent then those same entities would be unable to protect themselves from similar taxation by other states or municipalities - thus creating an unfair burden on interstate commerce which is protected under Article I of the Constitution. Finally, he concluded his dissent by noting how this ruling contradicted previous decisions made by both state and federal courts regarding similar issues and urged for greater consistency between them going forward.