In the case of Atchison, Topeka & Santa Fe Railway Company v. United States in 1913, the U.S. Supreme Court ruled that a railroad company could not charge more for a short haul than it did for a long one over the same line in the same direction unless authorized by public regulation commission after due investigation and hearing. The court held that this practice violated Section 4 of the Interstate Commerce Act which prohibited unjust discrimination between shippers similarly situated and undue preference or advantage to any particular person or locality. This decision was significant as it reinforced federal regulations aimed at preventing discriminatory pricing practices among railway companies.

In the dissenting opinion for Atchison, Topeka & Santa Fe Railway Company v. United States (1913), it was argued that the Interstate Commerce Commission's power should not extend to determining reasonable rates for railway companies. The dissenting justices believed this authority violated constitutional principles of separation of powers and due process rights. They contended that rate-setting is a legislative function, not an administrative one; thus, delegating such power to a commission infringes upon the legislature’s domain. Furthermore, they asserted that without judicial review or oversight on these decisions by the commission, there would be no safeguard against arbitrary or unreasonable determinations which could potentially harm businesses like railway companies. This lack of checks and balances in their view constituted a breach of due process rights as guaranteed under the Fifth Amendment.