In the Woodruff v. Mississippi case of 1895, the U.S Supreme Court ruled on a dispute involving state taxation and railroad property rights. The appellant, Woodruff, was a trustee for bondholders of the New Orleans, Jackson & Great Northern Railroad Company and contested against Mississippi's attempt to tax lands granted by Congress to aid in building railroads. He argued that these lands were exempt from state taxation under federal law until they had been sold or otherwise disposed of by the company. However, Mississippi countered this argument stating that once title passed from United States to any company or individual - regardless if it was still unsold land - it became subject to state taxes immediately as per their laws. The Supreme Court sided with Mississippi ruling that states have authority over all property within their borders not explicitly protected by federal statute or constitutional provision; thus upholding its right to levy taxes on such properties irrespective of whether they are held directly by individuals/companies or indirectly through trusteeship arrangements like those involved in this case.

In the dissenting opinion for Woodruff v. Mississippi, Justice Harlan argued that the majority's decision to uphold a state law imposing a tax on commercial agents selling goods by sample was in violation of the Constitution’s Commerce Clause. He believed this clause gave Congress exclusive power over interstate commerce and that states could not interfere with it through taxation or regulation. The justice maintained that such taxes were essentially tariffs between states, which are expressly prohibited by the Constitution. Furthermore, he contended that allowing individual states to impose their own regulations would lead to confusion and conflict among them, disrupting national unity and economic stability. Therefore, he disagreed with the majority's interpretation of federalism principles as permitting such state interference in interstate commerce.