The U.S. Supreme Court case Chicago, Milwaukee & St. Paul Railway Company v. City of Minneapolis in 1913 revolved around the issue of whether a city could require a railway company to make costly improvements to its infrastructure within the city's limits without violating the Fourteenth Amendment’s due process clause. The City of Minneapolis had ordered the railway company to construct and maintain viaducts over certain streets for public safety reasons, but at their own expense which was estimated at $80,000 (approximately $2 million today). The railroad argued that this order constituted an unlawful taking of property without just compensation. However, the Supreme Court ruled against them stating that such requirements were not unconstitutional as they fell under police power - government’s authority to enact laws for public welfare and safety - rather than eminent domain – government’s right to take private property for public use with fair compensation. Therefore, it did not violate due process rights under Fourteenth Amendment since it was reasonable regulation aimed at promoting community's health and safety.

In the dissenting opinion for the case of Chicago, Milwaukee & St. Paul Railway Company v. City of Minneapolis, Justice Holmes disagreed with the majority's ruling that a city ordinance requiring railroads to maintain and operate bridges over their tracks was unconstitutional. He argued that such an ordinance is within a municipality's police power as it pertains to public safety and welfare. Furthermore, he contended that this requirement did not constitute an undue burden on interstate commerce or violate due process rights under the Fourteenth Amendment because it merely required railway companies to bear costs associated with ensuring safe passage across their tracks - something they were already obligated to do by virtue of owning property used in ways potentially hazardous to public safety.