The U.S. Supreme Court case Atlantic Coast Line Railroad Co. v. Erie Lackawanna Railroad Co., et al., 1971, revolved around a dispute between multiple railroad companies over the division of revenue from joint rates on through routes (routes that cross several railroads). The Interstate Commerce Commission (ICC) had previously established divisions for these revenues but later changed them to be more equitable, which some railroads contested as being beyond the ICC's authority. The Supreme Court ruled in favor of the ICC, stating that it did have the power to alter previous divisions if they were found to be unjust or unreasonable and could establish new ones accordingly under sections 15(6) and 15a(3) of the Interstate Commerce Act.

In the dissenting opinion for Atlantic Coast Line Railroad Co. v. Erie Lackawanna Railroad Co., Justice Douglas argued that the majority's decision to allow a merger between two major railroad companies was not in line with antitrust laws and could potentially harm competition within the industry. He believed that such mergers should be scrutinized more closely, particularly when they involve large corporations with significant market power. Furthermore, he expressed concern over potential negative impacts on smaller railroads and other stakeholders who may suffer from reduced competition as a result of this merger. In his view, allowing these types of consolidations without thorough examination would set a dangerous precedent for future cases involving corporate mergers and acquisitions.