The U.S. Supreme Court case Winona and St. Peter Land Company v. Minnesota in 1895 revolved around a dispute over taxation of land granted by Congress to the state of Minnesota, which was then transferred to the Winona and St. Peter Land Company for railroad construction purposes. The company argued that under an 1857 act, these lands were exempt from taxation until they had been sold or contracted to be sold by them; however, the state imposed taxes on unsold portions of this land grant anyway. The court ruled in favor of Minnesota stating that while there was indeed an exemption clause within the Act, it only applied when lands were held directly by railroads themselves - not third-party corporations like Winona & St.Peter Land Co., even if those companies intended to use said lands for railroad-related purposes eventually. This decision upheld states' rights to tax federal land grants once they've been passed onto private entities and clarified how such exemptions should be interpreted moving forward.

In the dissenting opinion for Winona and St. Peter Land Company v. Minnesota, Justice Harlan argued that the majority's decision was a departure from established principles of constitutional law. He contended that it was not within the power of a state to tax property belonging to non-residents differently than residents' property without violating equal protection under the Fourteenth Amendment. The justice believed this case involved an unjustifiable discrimination against non-resident landowners, which he saw as unconstitutional class legislation prohibited by the Equal Protection Clause in the Constitution. Furthermore, he disagreed with how broadly his colleagues interpreted "due process," arguing instead for its more traditional understanding related to judicial proceedings rather than legislative acts like taxation policies.