In the case of Winona & St. Peter Land Company v. Minnesota, 1895, the U.S Supreme Court ruled in favor of the state of Minnesota. The dispute arose when Winona & St. Peter Land Company claimed that a tax imposed by Minnesota on lands granted to it by Congress was unconstitutional and violated its contract rights under federal law. However, the court held that while Congress had indeed granted land to railroads for construction purposes, this did not exempt them from taxation once they were sold or leased out for profit-making activities unrelated to railroad construction or operation. Therefore, such taxes did not infringe upon any contractual obligations between Congress and these companies as per their interpretation of federal laws at that time.

In the dissenting opinion for Winona & St. Peter Land Company v. Minnesota, Justice Harlan argued that the majority's decision was inconsistent with previous rulings of the Court and violated principles of federalism by allowing a state to tax property owned by a corporation chartered in another state. He contended that this ruling would open up corporations to double taxation as they could be taxed both in their home state and any other states where they own property. Furthermore, he pointed out that the land at issue had been granted to the company by Congress, making it subject only to federal jurisdiction until sold or otherwise disposed of according to congressional directives. Therefore, he believed Minnesota lacked authority over these lands for purposes of taxation.