The U.S. Supreme Court case All States Freight, Inc., et al. v. New York, New Haven & Hartford Railroad Co., et al., 1964 revolved around a dispute over freight charges between the railroad company and several shippers who had used its services. The shippers argued that they were entitled to refunds for certain payments made under protest due to an order from the Interstate Commerce Commission (ICC) which found the rates charged by the railroad company unreasonable and unlawful. However, this ICC decision was later reversed on appeal in federal court before it became effective or enforceable against anyone. In response to these claims, the Supreme Court held that since there was no final determination of unlawfulness by any competent authority at any relevant time when payments were made under protest, those payments did not become "unlawful exactions" entitling payors to restitution merely because of subsequent events such as reversal of ICC's decision on appeal after payment period ended.

In the dissenting opinion for All States Freight, Inc. v. New York, New Haven & Hartford Railroad Co., Justice Harlan argued that the majority's decision to allow a railroad company to abandon its operations without first obtaining approval from the Interstate Commerce Commission (ICC) was incorrect and could have serious implications on interstate commerce laws. He contended that such an interpretation of Section 1(18) of the Interstate Commerce Act would undermine ICC's authority over railroads' entry into or exit from markets, which is crucial in maintaining fair competition and protecting public interest. Furthermore, he pointed out that this ruling contradicted previous court decisions where it had been established that railroads cannot unilaterally cease their services without ICC’s permission even if they are losing money on those routes.