In the case of Atchison, Topeka & Santa Fe Railway Company v. United States in 1920, the U.S. Supreme Court ruled on a dispute involving railroad freight rates set by the Interstate Commerce Commission (ICC). The railway company challenged ICC's authority to establish these rates and claimed that they were discriminatory and violated their rights under the Due Process Clause of the Fifth Amendment. However, after reviewing evidence presented by both sides, including data about costs and revenues associated with different types of cargo transportations, as well as expert testimony regarding fair profit margins for rail companies operating under similar conditions, the court upheld ICC's rate-setting power. It concluded that there was no constitutional violation because Congress had granted this regulatory power to ensure reasonable charges for public services provided by private corporations like railroads which operated in an environment where competition did not effectively control prices or prevent abuses.

The dissenting opinion in the case of Atchison, Topeka & Santa Fe Railway Company v. United States argued that the Interstate Commerce Commission (ICC) did not have the authority to set rates for private rail companies. The dissenters believed that this power was reserved for Congress and should not be delegated to an administrative agency like the ICC. They contended that allowing such delegation would undermine constitutional checks and balances by giving too much legislative power to a non-legislative body. Furthermore, they expressed concerns about due process rights being violated if railroads were forced to comply with rates set by an entity other than Congress itself. This view held that only direct representatives of citizens could make decisions impacting property rights or economic interests of private entities.