The St. Louis, Cape Girardeau and Fort Smith Railway Company v. Missouri ex rel. Merriam case in 1894 revolved around the issue of taxation on railway property by the state of Missouri. The railway company argued that its property was being unfairly taxed at a higher rate than other properties within the state, violating their rights under both federal and state constitutions to equal protection under law and due process of law. However, upon review, it was found that there were no constitutional violations as all railroad companies were assessed uniformly according to their market value - which happened to be higher than most other types of real estate in the area - rather than arbitrarily or discriminatorily overtaxed compared with non-railroad properties. Therefore, this method did not infringe upon any constitutional protections afforded to them as they claimed.

In the dissenting opinion for the case of St. Louis, Cape Girardeau and Fort Smith Railway Company v. Missouri ex rel. Merriam, it was argued that a state's power to tax should not be limited by federal jurisdiction over interstate commerce unless such taxation directly interferes with this commerce. The dissenting justices contended that the majority decision effectively granted immunity from state taxation to corporations engaged in interstate commerce, which they believed was an unwarranted extension of federal authority at the expense of states' rights. They maintained that as long as a tax does not create direct burdens on interstate trade or discriminate against out-of-state entities, it should be permissible under constitutional law.