In the case of Corry v. The Mayor and Council of Baltimore (1904), the U.S Supreme Court ruled in favor of the city, upholding its right to regulate street railways. The plaintiff, Mr. Corry, was a shareholder in a railway company that had been granted permission by an 1860 ordinance to lay tracks on certain streets within Baltimore City for fifty years. However, subsequent ordinances passed by the city required all railroads operating within its limits to convert their operations from horse-drawn cars to electric power or face penalties including potential revocation of their rights-of-way. Corry argued these new requirements were unconstitutional as they violated his property rights without due process and impaired contractual obligations between his company and the city under Article I Section 10 Clause 1 (the Contract Clause) of US Constitution. The court rejected this argument stating that while franchises like those held by Corry's company are indeed contracts protected under this clause; such protection does not extend beyond reasonable regulation for public safety purposes which is what conversion from horse-drawn carriages to electric trams represented according to them.

The dissenting opinion in the case of Corry v. The Mayor and Council of Baltimore argued that the city's actions were unconstitutional, as they infringed upon private property rights without due process or just compensation. They contended that while a municipality has the right to make changes for public improvements, it must do so within constitutional limits. This includes providing fair compensation when taking or damaging private property for public use. In this case, they believed that Mr. Corry was not adequately compensated for his land which was taken by the city to widen a street - an act which significantly reduced its value and deprived him of its full use and enjoyment. Therefore, they disagreed with the majority's ruling upholding such municipal action as lawful under police power doctrine.