In the 1923 case, The Chastleton Corporation et al. v. Sinclair et al., Rent Commission of the District of Columbia, et al., the U.S Supreme Court ruled that a law passed during World War I to control rents in Washington D.C was no longer constitutional after wartime conditions had ended. The court held that while it is not within its power to determine whether an emergency still exists or has ceased which would justify legislation enacted under war powers, it can decide if circumstances have so changed since enactment as to render such legislation arbitrary or unreasonable and thus deprive citizens of their property without due process of law. This decision established a precedent for judicial review over laws initially justified by emergencies but later deemed unconstitutional when those emergencies are no longer present.

The dissenting opinion in the Chastleton Corporation v. Sinclair case argued that the Rent Commission of the District of Columbia was not unconstitutional and did not violate due process rights under the Fifth Amendment. The dissent maintained that it is within Congress's power to regulate rents during a housing emergency, as long as such regulation is reasonable and does not constitute confiscation. It further contended that courts should defer to legislative judgment on whether an emergency exists unless there is clear evidence to contradict this determination. In this case, they believed no such evidence existed; therefore, they disagreed with striking down rent control laws based on perceived lack of necessity or reasonableness at present time since these are matters for legislative discretion rather than judicial review.