In the 1931 case of Chicago, Rock Island & Pacific Railway Co. et al. v. United States et al., the U.S Supreme Court ruled on a dispute involving railway companies and their employees' wages during World War I period when railways were under federal control. The railway companies argued that they should not be held responsible for wage increases mandated by the Federal Railroad Administration because these decisions were made without their consent while under government control. However, the court upheld lower courts' rulings stating that despite being operated by the government at that time, railroads remained liable for any debts incurred including wage adjustments as they continued to receive benefits from operations such as profits after paying operating expenses and rentals due to them in accordance with federal legislation enacted during wartime.

In the dissenting opinion for the case of Chicago, Rock Island & Pacific Railway Co. et al. v. United States et al., Justice Stone argued that the Interstate Commerce Commission (ICC) had overstepped its authority by imposing a rate increase without sufficient evidence to justify it. He contended that while Congress granted ICC power to regulate railroad rates, this did not include an arbitrary ability to raise them without clear and convincing proof of necessity or fairness in relation to existing conditions and practices within the industry itself. The majority's decision effectively allowed ICC's judgment on economic matters related to railroads' financial stability override judicial review which he believed was contrary to principles of administrative law and due process rights under Constitution.