In the case of Yazoo and Mississippi Valley Railway Co. v. Adams in 1900, the U.S Supreme Court ruled on an issue related to taxation of railroad properties by states. The Yazoo and Mississippi Valley Railway Company challenged a tax imposed by the state of Mississippi, arguing that it was unconstitutional because it violated their charter which exempted them from any taxes beyond those specified within it. However, the court upheld the tax ruling against Yazoo's claim stating that such exemptions must be explicitly stated in statutory language or they do not exist; general implications are insufficient grounds for exemption claims. Therefore, unless there is clear evidence showing legislative intent to grant such immunity from taxation, companies cannot assume they have these privileges based solely on ambiguous interpretations of their charters.

In the dissenting opinion for Yazoo and Mississippi Valley Railway Co. v. Adams, it was argued that the majority's decision to uphold a state law taxing railroad companies differently from other corporations violated both due process and equal protection clauses of the Fourteenth Amendment. The dissenting justices believed that this tax law unfairly singled out railway companies for heavier taxation without any reasonable basis or justification, thus constituting an arbitrary exercise of power by the state legislature. They contended that all corporations should be treated equally under tax laws unless there is a clear public interest served by differential treatment - which they did not believe was demonstrated in this case. Furthermore, they expressed concern about potential negative impacts on interstate commerce if states were allowed to impose discriminatory taxes on transportation companies operating across state lines.