In the 1921 case of Commissioners of Road Improvement District No. 2 of Lafayette County, Arkansas v. St Louis Southwestern Railway Company, the U.S Supreme Court ruled in favor of the railway company. The dispute arose when a local road improvement district attempted to tax railroad property within its jurisdiction for road improvements that did not directly benefit the railway company's property. The court held that this taxation was unconstitutional as it violated both due process and equal protection clauses under Fourteenth Amendment rights by imposing an unfair burden on interstate commerce entities such as railroads without providing them with any direct benefits or advantages from these improvements.

In the dissenting opinion for Commissioners of Road Improvement District No. 2 of Lafayette County, Arkansas v. St Louis Southwestern Railway Company, it was argued that the majority's decision to uphold an assessment on a railway company for road improvements was unjust and unconstitutional. The dissenting justices believed that the railway should not be held responsible for these costs as they did not directly benefit from the road improvements in question. They contended that this ruling violated principles of equal protection under law by unfairly burdening one entity with costs which should have been shared among all beneficiaries of the improvement project. Furthermore, they expressed concern over potential abuses such a precedent could enable, where governments might arbitrarily impose taxes or assessments on businesses without clear justification or equitable distribution.