In Williams v. Supervisors of Albany, the Supreme Court of the United States was asked to decide whether a state law that allowed for the taxation of certain property owned by a corporation was constitutional. The plaintiff, Williams, argued that the law violated the Fourteenth Amendment of the United States Constitution, which states that no state shall “deny to any person within its jurisdiction the equal protection of the laws.” The Supreme Court held that the law was constitutional, finding that the law did not deny equal protection to any person. The Court reasoned that the law was a valid exercise of the state’s power to tax, and that the law did not discriminate against any particular class of persons. The Court also noted that the law was not arbitrary or capricious, and that it was applied equally to all corporations. Ultimately, the Supreme Court held that the law was constitutional, and that Williams’ Fourteenth Amendment claim was without merit. The Court’s decision established that states have the power to tax certain property owned by corporations, so long as the law is applied equally and does not discriminate against any particular class of persons.

In Williams v. Supervisors of Albany, the Supreme Court was tasked with determining whether a tax imposed by the state of New York on certain railroad companies violated the Constitution's Commerce Clause. The majority opinion held that it did not violate this clause and thus upheld the tax. However, Justice Field dissented from this decision and argued that such taxes were unconstitutional because they interfered with interstate commerce in violation of Congress' exclusive power to regulate it under Article I, Section 8 of the Constitution. He further noted that while states may impose taxes for revenue purposes, these must be uniform throughout their respective jurisdictions so as not to interfere with interstate commerce or discriminate against out-of-state businesses. Therefore he concluded that since New York had only taxed some railroads within its borders but not others similarly situated outside its jurisdiction, such taxation was an unconstitutional interference with interstate commerce and should have been struck down by the court instead of being upheld as valid legislation.