In the case of Carnation Co. v. Pacific Westbound Conference et al., 1965, the U.S Supreme Court ruled in favor of Carnation Company, a large food manufacturer and exporter. The company had filed suit against several ocean freight carriers that were part of the Pacific Westbound Conference (PWC), alleging they violated antitrust laws by collectively setting rates for shipping goods across the Pacific Ocean to Asia. PWC argued their actions were protected under an exemption granted by Federal Maritime Commission (FMC). However, this exemption was not yet approved at time when alleged violations occurred; thus it could not be used as defense in court proceedings. The Supreme Court held that until FMC formally approves such agreements between carriers, they are subject to antitrust laws just like any other business enterprise operating within United States jurisdiction. This ruling clarified legal boundaries regarding collective rate-setting among ocean freight carriers and emphasized importance of regulatory oversight from federal agencies like FMC.

The dissenting opinion in the case of Carnation Co. v. Pacific Westbound Conference et al., argued that the majority's decision to allow a private shipper to challenge a rate increase approved by the Federal Maritime Commission (FMC) was incorrect and potentially harmful for future cases. The dissent emphasized that Congress had given exclusive authority over shipping rates to FMC, which has expertise in this complex field, and courts should not interfere with its decisions unless there is evidence of clear illegality or abuse of power. They also pointed out that allowing shippers to sue could lead to endless litigation, disrupting commercial relationships and causing uncertainty about validly established rates. Moreover, they believed it was unfair for one company (Carnation) who disagreed with an increase agreed upon by all other members of a conference group, including many competitors, could unilaterally seek judicial review while others abide by collective agreements.