In the case of Wright v. Georgia Railroad and Banking Company (1909), the U.S Supreme Court ruled in favor of the Georgia Railroad and Banking Company, declaring that a state law requiring railroads to pay taxes on gross receipts from interstate commerce was unconstitutional. The court held that such taxation constituted an undue burden on interstate commerce, violating Article I, Section 8 of the Constitution which grants Congress exclusive power over this area. This decision reinforced federal supremacy over states in matters concerning interstate commerce regulation.

In the dissenting opinion for Wright v. Georgia Railroad and Banking Company, it was argued that the majority's decision to uphold a state law taxing railroad property differently from other types of property violated the Equal Protection Clause of the Fourteenth Amendment. The dissenting justices believed that all properties should be taxed equally regardless of their use or ownership status. They contended that allowing states to tax different properties at varying rates would lead to discrimination and unfair treatment under law, which is contrary to constitutional principles. Furthermore, they disagreed with the majority's interpretation of previous court decisions on similar issues, arguing those cases did not establish a precedent for unequal taxation based on property type.