In Railway Company v. United States, the Supreme Court was asked to decide whether the United States had the right to impose a tax on the gross receipts of a railway company. The railway company argued that the tax was unconstitutional because it violated the Fifth Amendment's prohibition against taking private property for public use without just compensation. The Supreme Court disagreed, holding that the tax was a valid exercise of the government's power to tax and did not constitute a taking of private property. The Court reasoned that the tax was imposed on the company's gross receipts, not on its property, and that the company was not deprived of its property without just compensation. The Court also noted that the tax was imposed on all companies operating in the same industry, and that the company was not singled out for special treatment. As such, the Court held that the tax was constitutional and did not constitute a taking of private property.

Justice Field delivered the dissenting opinion in Railway Company v. United States, arguing that Congress had no authority to impose a tax on railway companies for their transportation of passengers and freight. He argued that such taxation was an unconstitutional exercise of power by Congress because it violated the Fifth Amendment's prohibition against taking private property without just compensation. Furthermore, he argued that if this type of taxation were allowed, then there would be nothing preventing Congress from taxing any other form of business or activity they deemed necessary for public welfare. In conclusion, Justice Field believed that allowing this kind of taxation would lead to a dangerous precedent where the federal government could take away people’s rights with impunity and without due process or compensation.