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In the case of Chicago, Burlington & Quincy Railway Company v. United States in 1910, the U.S Supreme Court ruled on a dispute involving railway freight rates. The Interstate Commerce Commission (ICC) had ordered reduced rates for certain commodities transported by several railroads including the Chicago, Burlington & Quincy Railway Company. The railways argued that these reductions were so severe they violated their constitutional rights to property and due process under the Fifth Amendment because it would not allow them to earn a reasonable return on their investments. However, the Supreme Court upheld ICC's decision stating that courts should defer to administrative agencies' expertise in rate-setting matters unless its actions are clearly unreasonable or unlawful. This ruling affirmed ICC’s power over railroad companies and set an important precedent for future cases involving regulatory authority over private businesses.
In the dissenting opinion for Chicago, Burlington & Quincy Railway Company v. United States, Justice Harlan argued that the Interstate Commerce Commission (ICC) did not have the authority to set maximum rates for railroads. He believed this power was reserved solely for Congress and that it could not be delegated to a regulatory body like the ICC. Furthermore, he contended that even if such delegation were permissible, there should be judicial review of rate-setting decisions to prevent potential abuses of power by administrative bodies. This would ensure due process rights are upheld under law and protect private property from being taken without just compensation as guaranteed by the Fifth Amendment in U.S Constitution.