The U.S. Supreme Court case Railway Express Agency, Inc. v. Virginia in 1953 revolved around a dispute over interstate commerce and state taxation rights. The plaintiff, Railway Express Agency (REA), was an interstate carrier that transported goods across various states including Virginia where it had offices and vehicles for its operations but did not own any railroads or tracks within the state itself. REA challenged a tax imposed by the State of Virginia arguing that it violated the Commerce Clause of the Constitution as it interfered with interstate commerce. However, in this case, the Supreme Court upheld Virginia's right to impose taxes on REA's business activities within its jurisdiction despite their nature being part of larger interstate operations. The court ruled that while states cannot interfere with or discriminate against interstate commerce directly through taxation or regulation; they can levy taxes on businesses operating within their borders even if these businesses are involved in broader national commercial activities.

In the dissenting opinion for Railway Express Agency, Inc. v. Virginia, Justice Jackson disagreed with the majority's ruling that a state law prohibiting advertising on vehicles unless it was related to the business of the owner or lessee did not violate equal protection under the Fourteenth Amendment. He argued that this law was discriminatory and arbitrary because it allowed some businesses to advertise while preventing others from doing so without any rational basis for such distinction. According to him, there is no substantial difference between an advertisement placed by a vehicle owner about his own business and one placed by another person about their business in terms of public safety or aesthetics - which were cited as reasons behind this legislation. Therefore, he believed that this regulation violated equal protection rights guaranteed by Constitution since it treated similar entities differently without any reasonable justification.