In the case of Union Pacific Railroad Company v. Board of County Commissioners of Weld County, Colorado in 1917, the Supreme Court ruled on a dispute over taxation between a railroad company and county authorities. The Union Pacific Railroad Company had been taxed by Weld County for its rail lines that ran through several counties within Colorado. However, the company argued that this tax was unconstitutional as it violated their right to equal protection under law because other properties were not similarly taxed across multiple counties. The Supreme Court disagreed with Union Pacific's argument and upheld Weld County's right to levy taxes on property within its jurisdiction regardless if said property also extended into other jurisdictions (counties). This ruling affirmed local government’s authority to impose taxes on businesses operating within their boundaries even when those operations spanned across multiple jurisdictions.

In the dissenting opinion for Union Pacific Railroad Company v. Board of County Commissioners of Weld County, Colorado, it was argued that the majority's decision to allow states to tax railroad properties based on their full value rather than just a proportionate share contradicted previous rulings and principles established by the Court. The dissent emphasized that railroads operate across multiple jurisdictions and therefore should not be taxed as if they were entirely within one state or county. It was also pointed out that this ruling could lead to double taxation issues where multiple states claim taxing rights over the same property. Furthermore, it was contended that such an approach would unfairly burden interstate commerce in violation of constitutional principles.