In the 1916 case of Chicago, Milwaukee & St. Paul Railway Company of Idaho v. United States, the U.S Supreme Court ruled in favor of the federal government's right to regulate interstate commerce and transportation rates through its agency, the Interstate Commerce Commission (ICC). The railway company had challenged an order by ICC that reduced freight rates on certain commodities transported between specific points within states in North Dakota and Minnesota. The company argued that this was a violation of their Fifth Amendment rights as it amounted to confiscation without due process or just compensation. However, the court upheld ICC's authority under Congress' power to regulate interstate commerce provided for by Article I Section 8 Clause 3 of US Constitution - commonly known as "the Commerce Clause". This decision affirmed federal regulatory powers over private corporations involved in interstate trade activities.

In the dissenting opinion for Chicago, Milwaukee & St. Paul Railway Company of Idaho v. United States (1916), Justice Holmes disagreed with the majority's decision to uphold an order by the Interstate Commerce Commission that required railroads to provide free transportation for livestock caretakers. He argued that this requirement was not a reasonable regulation of commerce but rather amounted to unjust compensation without due process, violating the Fifth Amendment rights of railroad companies. Holmes believed it was inappropriate and unconstitutional for government regulators to force private businesses like railroads into providing services without payment or fair compensation in return, even if such services were deemed necessary for public welfare or safety considerations.