The U.S. Supreme Court case Board of Public Utility Commissioners v. Manila Electric Railroad & Light Company in 1918 revolved around the issue of whether or not a public utility commission had the authority to regulate rates charged by a foreign corporation operating within its jurisdiction. The Manila Electric Railroad and Light Company, an American-owned company operating in the Philippines, was ordered by the local Board of Public Utility Commissioners to reduce their rates for electricity and streetcar services. The company challenged this order on grounds that it violated their due process rights under both Philippine law and U.S federal law as they were chartered in New Jersey. The Supreme Court ruled against Manila Electric, upholding that while corporations have constitutional protections, these do not extend so far as to prevent regulation aimed at protecting public welfare - including rate regulations imposed by state utility commissions. This decision reinforced states' powers over businesses functioning within their borders even if those businesses are incorporated elsewhere.

In the dissenting opinion for the case of Board of Public Utility Commissioners v. Manila Electric Railroad & Light Company, Justice Holmes disagreed with the majority's decision to uphold a rate order issued by Philippine authorities against an American-owned utility company operating in Manila. He argued that while it was true that foreign countries had sovereignty over their territories and could regulate businesses within their jurisdiction, this did not mean they could arbitrarily confiscate property without due process or just compensation. In his view, such actions violated basic principles of justice and fairness recognized under international law. Furthermore, he contended that U.S courts should have jurisdiction to review such cases involving American companies abroad because these firms were entitled to protection under U.S laws and treaties even when operating overseas.