In the 1930 case of Atchison, Topeka & Santa Fe Railway Co. v. Railroad Commission of California et al., the U.S Supreme Court ruled in favor of the Atchison, Topeka & Santa Fe Railway Company (AT&SF). The dispute arose when AT&SF was ordered by the California Railroad Commission to construct a railway crossing at its own expense for another railroad company's use. AT&SF argued that this order violated their Fourteenth Amendment rights as it constituted an unlawful taking without just compensation and deprived them of property without due process. The court agreed with AT&SF stating that while states have power to regulate railroads within their jurisdiction, they cannot force one company to subsidize another’s operations without providing fair compensation or due process.

The dissenting opinion in the case of Atchison, Topeka & Santa Fe Railway Co. v. Railroad Commission of California et al., 1930 argued that the majority's decision was a departure from established principles governing interstate commerce and state power regulation. The dissenters believed that the State of California had overstepped its bounds by attempting to regulate rates for intrastate portions of continuous interstate hauls, which they saw as an infringement on federal authority under the Commerce Clause. They contended that such actions could lead to chaotic conditions if other states followed suit, with each trying to control some portion or aspect of national transportation systems based on local interests rather than a unified national policy. Furthermore, they disagreed with the majority's interpretation and application of previous court decisions related to this issue.