In the 1962 case Arrow Transportation Co. et al. v. Southern Railway Co. et al., the U.S Supreme Court ruled in favor of Southern Railway Company and other railroads, dismissing a complaint filed by Arrow Transportation Company and other barge lines operating on Tennessee River System (plaintiffs). The plaintiffs accused the defendants of violating Sections 1 and 3 of Sherman Act by conspiring to monopolize interstate commerce through discriminatory railroad rates designed to eliminate competition from water carriers for transportation of petroleum products from southeastern refineries to points in Alabama, Georgia, North Carolina, South Carolina, Kentucky and Virginia (the Southeastern Territory). However, after examining evidence presented at trial court level which included rate structures over a period of years as well as market conditions such as demand for services or availability thereof among others; it was concluded that there was no sufficient proof showing any conspiracy or intent on part of defendant railroads towards monopolization.

In the dissenting opinion for Arrow Transportation Co. et al. v. Southern Railway Co., it was argued that the Interstate Commerce Commission (ICC) had not exceeded its authority in approving a joint rate proposed by rail and barge carriers, as claimed by the majority ruling. The dissenting justices believed that ICC's approval of such rates did not constitute an unlawful delegation of legislative power to private parties, but rather fell within ICC's statutory mandate to ensure reasonable and nondiscriminatory transportation rates. They also disagreed with the majority's view that this case involved a "new species" of rate-making; instead, they saw it as part of longstanding practices where different types of carriers cooperated on through routes and joint rates under ICC supervision.