The State of Maryland, for the use of Washington County, brought a case against The Baltimore and Ohio Railroad Company in which they argued that the railroad had not paid taxes on certain lands. The state claimed that these lands were taxable under an act passed by Congress in 1828. However, the defendants argued that this act did not apply to them because it was unconstitutional due to its interference with private contracts between individuals and corporations. After much deliberation, the Supreme Court ruled in favor of The Baltimore and Ohio Railroad Company stating that Congress could not interfere with such contracts as it would be a violation of their rights under Article I Section 10 Clause 1 of the Constitution. This ruling set an important precedent regarding states' abilities to tax land owned by corporations or other entities protected from taxation by federal law.

In the dissenting opinion of this case, Justice Catron argued that the state of Maryland had no right to bring a suit against the Baltimore and Ohio Railroad Company. He reasoned that since Congress had granted exclusive authority over interstate commerce to itself, it was not within Maryland's power or jurisdiction to interfere with such matters. Furthermore, he asserted that if states were allowed to regulate interstate commerce in any way they saw fit then there would be chaos as each state could impose its own laws on goods passing through their borders. Therefore, he concluded that only Congress has the power and authority necessary for regulating interstate commerce and thus Maryland should not have been permitted to bring a suit against The Baltimore and Ohio Railroad Company.