In the 1911 case of Seaboard Air Line Railway v. Duval, the United States Supreme Court ruled in favor of Seaboard Air Line Railway. The dispute arose when Duval, a tax collector for Hillsborough County in Florida, attempted to collect taxes on railway cars that were owned by companies outside of Florida but used by Seaboard within the state. The court held that these cars could not be taxed because they were considered interstate commerce and thus protected under federal law from being subjected to state taxation. This decision reinforced previous rulings which established that states cannot interfere with or impose burdens on interstate commerce.

In the dissenting opinion for Seaboard Air Line Railway v. Duval, it was argued that the majority's decision to uphold a Florida law requiring railroads to pay damages for livestock killed on their tracks, even if they were not negligent, violated the Fourteenth Amendment. The dissenting justices believed this ruling unfairly imposed an absolute liability on railroad companies without providing them with any means of protecting themselves against such losses. They contended that this constituted a deprivation of property without due process of law and infringed upon interstate commerce by creating additional operating costs for railway companies crossing state lines. Furthermore, they disagreed with the majority's interpretation that these laws served as safety regulations rather than penalties or revenue sources for states.