The U.S. Supreme Court case Chicago, Indianapolis & Louisville Railway Company et al. v. United States et al., 1925, revolved around the issue of whether or not a railway company could be compelled to provide services that were unprofitable and resulted in losses for the company under the Interstate Commerce Act (ICA). The Chicago, Indianapolis & Louisville Railway Company had been ordered by the Interstate Commerce Commission (ICC) to continue providing passenger train service on certain routes despite these being financially detrimental to them. The railway company argued this was an abuse of power by ICC and violated their rights as it forced them into involuntary servitude contrary to the Thirteenth Amendment. However, upon review, the Supreme Court upheld ICC's order stating that public convenience and necessity outweighed any financial loss suffered by railroad companies under ICA regulations. It ruled that railroads are bound as public utilities to serve where necessary even if such service is rendered at a loss.

In the dissenting opinion for the case of Chicago, Indianapolis & Louisville Railway Company et al. v. United States et al., Justice McReynolds argued that the Interstate Commerce Commission (ICC) had overstepped its bounds by ordering a reduction in rates without sufficient evidence to justify such action. He contended that while it was within ICC's power to ensure just and reasonable rates, this did not give them carte blanche authority to arbitrarily lower prices based on mere speculation or conjecture about potential future conditions. The justice believed there should be concrete proof of existing unfairness before any rate adjustments were made, emphasizing due process rights under law for railroads as well as shippers and consumers.