In the case of Coulter v. Louisville and Nashville Railroad Company, the U.S Supreme Court in 1904 ruled on a dispute involving railroad freight charges. The plaintiff, Coulter, had shipped goods via the defendant's rail line under an agreement that he would pay less than the published tariff rates for freight services. However, after delivery of his goods, he was charged at full tariff rates instead of agreed upon lower rate. He sued to recover overcharges but lost in both lower courts as they held that agreements charging less than published tariffs were illegal under Interstate Commerce Act (1887). Upon appeal to Supreme Court by Coulter arguing that such interpretation is unjust and unreasonable; it upheld previous rulings stating any deviation from publicly posted tariffs - even if it benefits customers with reduced prices - undermines uniformity intended by Congress when passing Interstate Commerce Act which aimed to prevent price discrimination or preferential treatment among shippers.

In the dissenting opinion for Coulter v. Louisville and Nashville Railroad Company, it was argued that the majority's decision contradicted established principles of law regarding interstate commerce regulation. The dissent contended that states should retain their authority to regulate matters within their borders unless federal legislation explicitly preempts state laws. In this case, there was no such explicit federal statute overriding Kentucky's ability to enforce its own regulations on railroad companies operating within its territory. Therefore, according to the dissenting justices, Kentucky had every right to impose safety requirements on trains traveling through its jurisdiction even if those trains were engaged in interstate commerce. They believed that allowing a state like Kentucky to ensure safe railway operations did not interfere with Congress' power over interstate commerce but rather complemented it by filling regulatory gaps left by Congress.