In United States v. Railroad Company, the Supreme Court of the United States was asked to decide whether the United States had the right to impose a tax on a railroad company. The railroad company argued that the tax was unconstitutional because it was a direct tax, which the Constitution prohibited. The Supreme Court disagreed, ruling that the tax was not a direct tax, but an excise tax, which was allowed under the Constitution. The Court held that the tax was valid because it was imposed on the privilege of operating a railroad, and not on the property of the railroad company. The Court also held that the tax was not a burden on interstate commerce, as the railroad company had argued. The Court's decision established that the federal government had the power to impose taxes on businesses, and that the Constitution did not prohibit such taxes.

In United States v. Railroad Company, the Supreme Court was asked to decide whether a federal statute that granted land rights to railroad companies preempted state laws governing those same lands. The majority opinion held that the federal law did indeed preempt state laws in this case, and thus affirmed the lower court's ruling in favor of the railroad company. However, Justice Field dissented from this decision on two grounds: firstly, he argued that Congress had not intended for its legislation to supersede existing state laws; and secondly, he asserted that such an interpretation would be unconstitutional as it would violate states' rights under the Tenth Amendment. In conclusion, Justice Field believed that Congress could only override existing state law if it explicitly stated so within its legislation - which was not done here - or if there were some other constitutional basis for doing so - which also did not exist here.