In the case of Baltimore & Ohio Railroad Company v. United States ex rel. Pitcairn Coal Company, 1909, the Supreme Court ruled on a dispute between coal companies and railroads over freight rates under the Hepburn Act of 1906. The act gave power to the Interstate Commerce Commission (ICC) to set maximum railroad rates after hearing complaints from shippers who believed they were being charged unfairly high prices for transport services by railroads. In this particular case, several coal companies alleged that their shipping costs had been unjustly increased by certain railroad corporations including Baltimore & Ohio Railroad Company. They sought relief through ICC which ordered reduced rates but was challenged in court by these railroads arguing that ICC lacked constitutional authority to enforce such reductions without judicial review or due process protections for them as carriers. The Supreme Court upheld ICC's decision stating it did not infringe upon any constitutional rights of carriers nor required judicial intervention since its function was administrative rather than judicial in nature; thus confirming broad regulatory powers granted to federal agencies like ICC under Hepburn Act.

In the dissenting opinion for Baltimore & Ohio Railroad Company v. United States Ex Rel. Pitcairn Coal Company, Justice Harlan argued that the Interstate Commerce Commission (ICC) had overstepped its authority by ordering a reduction in freight rates without sufficient evidence of unreasonableness or discrimination on part of the railroad company. He contended that while ICC has regulatory power, it should not interfere with private business contracts unless there is clear proof of violation against public interest or law. The majority's decision to uphold ICC's order was seen as an unwarranted intrusion into private contractual agreements and could potentially undermine free market principles if left unchecked.