In the case of Barrett, as President of The Adams Express Company v. Van Pelt in 1924, the U.S Supreme Court ruled on a dispute involving stockholder rights and corporate governance. The plaintiff, Mr. Van Pelt was a shareholder in the Adams Express Company who sued its president, Mr. Barrett for alleged mismanagement of company assets and violation of his fiduciary duties to shareholders by investing heavily into railroad bonds without proper authorization from shareholders or directors. He sought an injunction to prevent further investments and damages for losses incurred due to these unauthorized transactions. The court held that while corporate officers have broad discretion over business decisions under the "business judgment rule", they must still act within their authority granted by law or company charter; any actions beyond this may be subject to judicial review if it results in harm or potential harm to stakeholders' interests. However, since there was no evidence showing that such investments were made recklessly or with fraudulent intent nor did it cause actual financial loss at time suit was filed (as those bonds had appreciated), court found no breach of duty occurred here despite lack of formal approval process being followed before making said investment decisions.

In the dissenting opinion for Barrett, as President of The Adams Express Company v. Van Pelt, Justice McReynolds disagreed with the majority's interpretation of the Commerce Clause and its application to this case. He argued that Congress did not have unlimited power to regulate commerce between states and believed that it was a mistake to allow federal control over intrastate transactions simply because they might indirectly affect interstate commerce. In his view, such an expansive reading of Congressional authority could lead to excessive federal regulation in areas traditionally reserved for state law. Furthermore, he contended that there was no evidence presented in this case showing any substantial effect on interstate commerce resulting from New York’s tax laws applied on express companies like Adams Express Company.