The U.S. Supreme Court case Cleveland, Cincinnati, Chicago and St. Louis Railway Company v. Illinois in 1899 revolved around the issue of whether a state could regulate interstate commerce rates for railroads within its borders without violating the Commerce Clause of the Constitution which gives Congress exclusive power to regulate interstate commerce. The railway company argued that an Illinois law setting maximum rates for transportation was unconstitutional as it interfered with interstate commerce regulation by Congress. However, the court ruled against them stating that until Congress acted to set such rates itself or prohibit states from doing so, states were free to enact their own regulations on railroad charges within their boundaries even if they affected interstate trade indirectly.

In the dissenting opinion for Cleveland, Cincinnati, Chicago and St. Louis Railway Company v. Illinois (1899), Justice Harlan argued that the majority's decision was a departure from established principles of constitutional law. He contended that it allowed states to interfere with interstate commerce in ways not permitted by previous rulings or intended by the framers of the Constitution. Harlan believed that railroads were instrumentalities of interstate commerce and thus should be protected from state regulation under federal jurisdiction as per Commerce Clause in U.S constitution. The justice also expressed concern about potential negative impacts on national uniformity if individual states could regulate rates for railroad companies operating across multiple jurisdictions.