The U.S. Supreme Court case Arizona Grocery Co. v. Atchison, Topeka & Santa Fe Railway Co., et al., 1931 revolved around the issue of whether a shipper could challenge a rate established by the Interstate Commerce Commission (ICC) as being too high even after it had been approved by the ICC as just and reasonable. The Arizona Grocery Company argued that they should be allowed to seek reparations for what they believed were excessive rates charged by several railway companies including Atchison, Topeka & Santa Fe Railway Co.. However, in their decision, the Supreme Court sided with the railways and upheld that once a rate is deemed fair and reasonable by ICC, it cannot be challenged in court on grounds of being unreasonable or discriminatory under sections 8 and 9 of Interstate Commerce Act unless there's evidence proving unreasonableness at time when order was made effective.

The dissenting opinion in the case of Arizona Grocery Co. v. Atchison, Topeka & Santa Fe Railway Co., et al., argued that the majority's decision to uphold a reparation order from the Interstate Commerce Commission (ICC) was incorrect because it failed to properly consider whether or not there had been an unreasonable practice by the railway company. The dissent pointed out that while rates may have been higher than those charged for similar distances elsewhere, this did not necessarily mean they were unjust or unreasonable when considering all relevant factors such as cost and value of service provided. Furthermore, it was suggested that if every instance where rates are found to be higher than average is deemed unreasonable and subject to reparations, then this would essentially result in nationwide rate regulation by averaging - something which Congress has never authorized nor intended with its legislation governing interstate commerce.