The Rochester Railway Company v. City of Rochester case in 1906 revolved around a dispute between the railway company and the city over taxation. The railway company argued that it was being unfairly taxed by the city, which had imposed taxes on its gross earnings from both within and outside of Rochester's limits. The Supreme Court ruled in favor of the City of Rochester, stating that as long as a tax is not discriminatory or violates interstate commerce laws, it can be levied on all income sources regardless if they are derived from intrastate or interstate operations. This ruling established an important precedent for how businesses operating across state lines could be taxed by local jurisdictions.

In the dissenting opinion for Rochester Railway Company v. City of Rochester, it was argued that the city did not have the right to impose conditions on a railway company's use of public streets without providing compensation. The justice believed that such an imposition constituted a taking of private property for public use without just compensation, which is in violation of the Fourteenth Amendment. He also expressed concern about setting a precedent where municipalities could arbitrarily interfere with businesses operating under state-granted franchises by imposing new and potentially burdensome regulations or requirements. This would undermine contractual obligations and disrupt established business operations, leading to uncertainty and instability in commercial activities.