This case was a dispute between the Liverpool, New York and Philadelphia Steamship Company and the Commissioners of Emigration. The company had been transporting passengers from Europe to the United States, and the Commissioners had imposed a fee on the company for each passenger. The company argued that the fee was unconstitutional, as it was a tax on immigration and thus a violation of the Commerce Clause of the Constitution. The Supreme Court agreed with the company, ruling that the fee was unconstitutional and that the Commissioners had no authority to impose it. The Court held that the fee was a tax on immigration, and thus was a violation of the Commerce Clause. The Court also held that the fee was not a valid exercise of the power of the state to regulate immigration, as it was not a reasonable exercise of the state's power. The Court thus ruled that the fee was unconstitutional and that the Commissioners had no authority to impose it.

In Liverpool, New York and Philadelphia Steamship Company v. Commissioners of Emigration, the Supreme Court was asked to decide whether a state law that imposed an annual tax on steamships for each passenger they carried from foreign ports into the United States violated federal laws regulating immigration. The majority opinion held that it did not violate those laws because Congress had not expressly prohibited such taxation. Justice Field dissented, arguing that while Congress had not explicitly forbidden states from imposing taxes on immigrants entering their borders, this should be implied in light of its power to regulate immigration under the Constitution and its intent to protect immigrants against exploitation by state governments. He argued further that allowing states to impose these kinds of taxes would lead them down a slippery slope towards more oppressive regulations which could interfere with congressional authority over immigration matters and ultimately harm both citizens and non-citizens alike who are seeking entry into the country.