In the case of Chesapeake & Ohio Railway Company v. Public Service Commission of the State of West Virginia, 1916, the U.S Supreme Court ruled in favor of Chesapeake & Ohio Railway Company. The court held that a state public service commission could not enforce an order requiring a railroad company to install safety appliances on its trains without approval from the Interstate Commerce Commission (ICC). The ICC was established by Congress to regulate interstate commerce and had exclusive jurisdiction over such matters. Therefore, any decision regarding safety equipment installation should be made by this federal body rather than individual states' commissions. This ruling reinforced federal supremacy in regulating interstate commerce and limited states' powers in these areas.

The dissenting opinion in the case of Chesapeake & Ohio Railway Company v. Public Service Commission of West Virginia argued that the state had a right to regulate railway rates within its borders, even if those railways were part of interstate systems. The justice disagreed with the majority's interpretation of federal law as preempting state regulation, arguing instead for a more balanced approach that recognized both federal and state interests. He believed that states should have authority over local matters unless there was clear evidence that Congress intended to override this authority. In his view, allowing states to set reasonable rates would not interfere with interstate commerce but rather promote it by ensuring fair competition among railroads.