In the case of Darnell v. Edwards et al., constituting the Mississippi Railroad Commission, 1916, the U.S. Supreme Court was asked to determine whether a state law that required railroads to provide separate but equal accommodations for black and white passengers violated the Fourteenth Amendment's Equal Protection Clause. The plaintiff, Darnell, argued that he had been discriminated against based on his race when he was forced to ride in a segregated car while traveling within Mississippi. However, the court ruled in favor of Edwards and others who constituted the Mississippi Railroad Commission by upholding segregation laws under "separate but equal" doctrine established earlier in Plessy v Ferguson (1896). The court held that as long as facilities were substantially equivalent there wasn't any violation of constitutional rights.

In the dissenting opinion for Darnell v. Edwards et al., it was argued that the Mississippi Railroad Commission did not have the authority to regulate interstate commerce, which included setting rates for railroads operating within its jurisdiction. The dissenting justices believed this power belonged solely to Congress under Article I of the Constitution and that states could only regulate matters of local concern. They also contended that allowing state commissions such as Mississippi's to set railroad rates would lead to a chaotic system with different rules in every state, undermining uniformity in national transportation policy. Furthermore, they disagreed with majority’s interpretation of previous court rulings on similar issues and expressed concerns about potential violations of due process rights if states were allowed unchecked regulatory powers over interstate commerce.