In the case of Wright, Comptroller General of Georgia v. Central of Georgia Railway Company (1914), the U.S Supreme Court dealt with a dispute over taxation between the state and a railway company. The State of Georgia had imposed taxes on all railroads operating within its borders, including those owned by out-of-state companies like Central of Georgia Railway Company. The railway company argued that this was unconstitutional as it violated their rights under both the Commerce Clause and Fourteenth Amendment's Equal Protection Clause because they were being taxed at higher rates than in-state companies. The Supreme Court ruled in favor of Wright, upholding the constitutionality of Georgia’s tax law. It held that states have broad powers to levy taxes for public purposes unless there is clear infringement upon federal authority or violation against specific constitutional prohibitions. In this case, no such infringements or violations were found; hence, it did not violate either clause mentioned above.

In the dissenting opinion for Wright, Comptroller General of Georgia v. Central of Georgia Railway Company, Justice Holmes disagreed with the majority's ruling that a state tax on railway property was unconstitutional due to its interference with interstate commerce. He argued that there is no constitutional principle preventing states from taxing property within their borders just because it is used in interstate commerce. According to him, if such taxation were prohibited then all properties involved in any form of trade would be exempted from taxes which he considered absurd and impractical. Furthermore, he contended that the Commerce Clause does not grant immunity from fair and non-discriminatory state taxation but rather prevents states from imposing burdensome regulations or discriminatory taxes on out-of-state entities engaging in interstate business activities.