In the 1891 case of Chicago & Grand Trunk Railway Company v. Wellman, the U.S. Supreme Court ruled in favor of the railway company, stating that it was not obligated to provide a lower rate for transporting goods than what was stipulated by law. The plaintiff, Wellman, had argued that he should be given a reduced rate because he shipped large quantities of grain regularly and thus contributed significantly to the railway's business. However, Justice Horace Gray delivered an opinion on behalf of a unanimous court asserting that there is no legal obligation for any public carrier to offer preferential rates based on quantity or frequency unless explicitly stated by statute or contract. This decision reinforced principles related to fair trade practices and non-discrimination in pricing among customers.

In the dissenting opinion for Chicago & Grand Trunk Railway Company v. Wellman, Justice Brewer argued that the majority's decision was based on a misinterpretation of the Interstate Commerce Act. He contended that Congress intended to prevent unjust discrimination between shippers and did not intend to regulate what railroads could charge for services provided solely within one state. According to him, if a railroad company chooses to offer lower rates for longer distances or larger quantities as part of its business strategy, it should be allowed to do so without being accused of violating federal law simply because some customers might benefit more than others from these discounts. He also pointed out that there is no evidence in this case showing any intent by the railway company to discriminate against certain customers unfairly or arbitrarily.