In the 1904 case of Board of Trade of the City of Chicago v. Christie Grain and Stock Company, the U.S. Supreme Court upheld a rule established by the Chicago Board of Trade that prohibited its members from engaging in grain trading after regular business hours (known as "after-hours" or "call" trading). The court ruled that this prohibition was not an unreasonable restraint on trade under antitrust laws because it served to prevent market manipulation and maintain fair competition among traders. This decision marked one of the first times that courts recognized self-regulatory organizations' ability to establish rules for their members, setting a precedent for future cases involving securities exchanges and other financial markets.

In the dissenting opinion for the case of Board of Trade of The City Of Chicago v. Christie Grain and Stock Company, Justice Brewer argued that there was no violation in terms of trade or commerce. He believed that the closing rule implemented by the Board did not create a monopoly nor restrain trade but rather facilitated it by providing an orderly system to conduct business transactions. Furthermore, he asserted that this rule was necessary to prevent manipulation and speculation which could harm both buyers and sellers in grain trading markets. He also pointed out that such rules were common among other boards across different cities indicating their necessity for smooth operations within these exchanges.