In the case of Chicago & Alton Railroad Company v. United States (1917), the U.S Supreme Court upheld a ruling that allowed for increased regulation of railroad companies by federal authorities. The Chicago & Alton Railroad Company had challenged an order from the Interstate Commerce Commission, which required all railroads to equip their cars with "automatic couplers" and other safety appliances in compliance with the Safety Appliance Act of 1893. The company argued that this was beyond Congress's power under the Commerce Clause as it amounted to direct regulation rather than indirect control over interstate commerce. However, Justice Day delivered a unanimous decision rejecting these arguments and affirming that such regulations were within Congress’s constitutional authority because they directly related to public safety in interstate commerce operations.

In the dissenting opinion for Chicago & Alton Railroad Company v. United States, Justice McReynolds disagreed with the majority's decision that a railroad company could be held liable under the Elkins Act for giving rebates to shippers. He argued that there was no evidence of intent on part of the railroad company to give preferential treatment or discriminate against other customers, which he believed was necessary for a violation under this act. Furthermore, he contended that any discrepancies in shipping rates were due to honest mistakes and not deliberate actions by the company. Therefore, according to him, it would be unjust and contrary to legal principles if an entity is penalized without proof of wrongful intention or conduct.