In the case of Burleson, Postmaster General v. Dempcy et al., constituting the Public Utilities Commission of Illinois, et al., 1918, the U.S Supreme Court was tasked with determining whether or not a state public utilities commission had jurisdiction over rates charged by telegraph companies for interstate messages. The court ruled in favor of Burleson and held that states do not have authority to regulate rates for interstate communications as this power is reserved exclusively to Congress under the Commerce Clause of the Constitution. This decision reinforced federal supremacy over interstate commerce and limited state regulatory powers in such matters.

In the dissenting opinion for Burleson v. Dempcy, Justice Holmes argued that the federal government had overstepped its authority by interfering with a state's right to regulate its own public utilities. He contended that while Congress has broad powers under the Commerce Clause, it does not have unlimited power to interfere in matters traditionally left to states' discretion. In this case, he believed Illinois should retain control over regulating telephone rates within its borders and objected to what he saw as an unwarranted intrusion of federal power into state affairs. Furthermore, he expressed concern about potential abuses of such expansive interpretations of federal authority and cautioned against setting a precedent that could undermine states' rights in future cases.