The U.S. Supreme Court case Risty et al., County Commissioners, et al. v. Chicago, Rock Island & Pacific Railway Company in 1925 revolved around the issue of taxation on railway properties by local authorities in South Dakota. The plaintiffs (Risty and other county commissioners) claimed that the defendant (Chicago, Rock Island & Pacific Railway Company) owed unpaid taxes for its property within their jurisdiction based on an assessment they had made. However, the railway company argued that it was not liable to pay these taxes as it believed them to be unjustly high and discriminatory compared to what other commercial entities were charged under similar circumstances. The court ruled in favor of the railway company stating that while states have a right to tax businesses operating within their boundaries, such taxation must be fair and uniform across all types of businesses without any discrimination or bias towards specific industries or companies.

The dissenting opinion in the case of Risty et al., County Commissioners, et al. v. Chicago, Rock Island & Pacific Railway Company argued that the majority's decision to uphold a lower court ruling allowing the railway company to avoid paying certain taxes was incorrect. The dissenters believed that this interpretation of law unfairly favored corporations over individual taxpayers and local governments. They contended that railroads should not be exempt from taxation simply because they are involved in interstate commerce, as all businesses contribute to public infrastructure through their operations and thus should share in its costs. Furthermore, they asserted that such exemptions could lead to significant revenue losses for states and municipalities which rely heavily on property tax income from large corporations like railways.