In the 1947 case Seaboard Air Line Railroad Co. v. Daniel, Attorney General, et al., the United States Supreme Court ruled in favor of Seaboard Air Line Railroad Company (SAL). The issue at hand was whether a Georgia state law that required railroads to pay for grade-crossing eliminations constituted an undue burden on interstate commerce and thus violated the Commerce Clause of the U.S. Constitution. SAL argued that it should not be solely responsible for these costs as they were public improvements benefiting all citizens, not just railroad companies. The court agreed with SAL's argument and held that while states have power to regulate local aspects of railway safety, they cannot impose financial burdens on railroads which effectively control or influence interstate commerce operations without violating federal jurisdiction over such matters under the Commerce Clause.

In the dissenting opinion for Seaboard Air Line Railroad Co. v. Daniel, Attorney General, et al., Justice Frankfurter argued that the majority's decision to invalidate a state tax on interstate commerce was incorrect and overstepped their authority. He contended that it is not within the Court's jurisdiction to determine whether or not a tax is fair or reasonable; this responsibility lies with legislative bodies who have been elected by citizens to make such decisions. Furthermore, he asserted that there was no evidence of discrimination against interstate commerce in this case as all businesses were subject to the same taxation rules regardless of whether they operated solely within South Carolina or across state lines. Therefore, according to Justice Frankfurter, there was no violation of constitutional principles and thus no grounds for invalidating the tax.