The U.S. Supreme Court case Rowley, Treasurer of Converse County, Wyoming, et al. v. Chicago & Northwestern Railway Co., 1934 revolved around the issue of taxation on interstate commerce and its potential violation of the Commerce Clause in the Constitution. The state of Wyoming had imposed a tax on fuel used by railway companies within their borders; however, this was challenged by Chicago & Northwestern Railway Company who argued that such a tax interfered with interstate commerce and thus violated federal law under the Commerce Clause which gives Congress exclusive power to regulate trade between states. The court ruled in favor of Chicago & Northwestern Railway Co., stating that while states have some authority to levy taxes for services provided within their jurisdiction, they cannot impose taxes that discriminate against or unduly burden interstate commerce.

In the dissenting opinion for Rowley v. Chicago & Northwestern Railway Co., Justice Stone argued that the majority's decision was inconsistent with previous rulings and principles of constitutional law. He contended that a state has the right to tax property within its borders, even if it is used in interstate commerce, as long as it does not discriminate against or unduly burden such commerce. In this case, he believed Wyoming had fairly assessed taxes on railroad properties based on their value and use within the state. The fact that these properties were also part of an interstate network did not exempt them from taxation under federal law or constitutionally prohibit states from taxing them at rates applied to other similar types of property in-state. Therefore, he disagreed with the majority's ruling which held Wyoming’s method for assessing railway company’s taxable assets unconstitutional because they included out-of-state values.