In the case of Chicago & Northwestern Railway Company v. United States, 1917, the U.S. Supreme Court was tasked with determining whether a federal law that required railroads to equip their cars with safety appliances was constitutional and if it applied to intrastate commerce as well as interstate commerce. The railway company argued that this requirement constituted an undue burden on intrastate commerce and thus violated states' rights under the Constitution's Commerce Clause. The court ruled in favor of the United States government, upholding both the constitutionality of such regulations and their application to intrastate traffic when it is part of a continuous interstate journey. The decision affirmed Congress’s power under its Commerce Clause authority to regulate not only direct but also closely related aspects affecting interstate trade or transportation for public safety purposes even though they might occur within state boundaries.

The dissenting opinion in the case of Chicago & Northwestern Railway Company v. United States argued that the Interstate Commerce Commission (ICC) had overstepped its bounds by ordering railroads to establish physical connections where none previously existed. The dissenters believed that this was not a matter of regulation, but rather an imposition on private property rights without just compensation, which they saw as unconstitutional. They contended that while the ICC could regulate rates and prevent discrimination or unfair practices, it did not have authority to mandate structural changes or improvements to railroad properties. This power should be left with Congress or state legislatures who can provide appropriate compensation for such impositions on private property rights.