The U.S. Supreme Court case Atchison, Topeka & Santa Fe Railway Company v. Swearingen in 1915 revolved around a dispute over the interpretation of an interstate commerce law related to freight rates for shipping goods by rail. The railway company had charged Swearingen different rates for shipments that were essentially the same distance but involved crossing state lines, which Swearingen argued was discriminatory and violated federal law. The court ruled in favor of the railway company, stating that it was within its rights to charge different rates based on whether or not a shipment crossed state lines because this constituted a significant difference in service provided by the railroad due to additional administrative costs associated with interstate transport.

In the dissenting opinion for Atchison, Topeka & Santa Fe Railway Company v. Swearingen, Justice Holmes disagreed with the majority's decision to uphold a Kansas statute that allowed shippers to recover damages from railroads for any delay in shipping goods. He argued that such laws were unconstitutional because they interfered with interstate commerce and violated the Due Process Clause of the Fourteenth Amendment. He believed it was unfair to hold railroads responsible for delays caused by factors beyond their control like weather or mechanical failures. Furthermore, he contended that if every state enacted similar legislation, it would create an unmanageable patchwork of regulations which could potentially cripple interstate commerce. Therefore, he concluded that federal regulation was necessary in this area rather than individual state laws.