The Dayton-Goose Creek Railway Company v. United States, Interstate Commerce Commission case in 1923 revolved around the issue of whether a railway company could be exempted from long and short haul clauses under the Interstate Commerce Act. The Dayton-Goose Creek Railway Company argued that it should be exempt due to its primary function being industrial rather than commercial transportation. However, the Supreme Court ruled against this argument stating that regardless of its primary use for industrial purposes, since it was also engaged in interstate commerce transportations, it fell within the purview of federal regulation as per the act. Therefore, no exemption could be granted based on their claim.

In the dissenting opinion for Dayton-Goose Creek Railway Company v. United States, Justice McReynolds disagreed with the majority's decision that Interstate Commerce Commission (ICC) had jurisdiction over intrastate railroads if their operations affected interstate commerce. He argued that this interpretation was an unwarranted expansion of federal power and a violation of states' rights to regulate their own internal affairs. The justice contended that there was no evidence showing any substantial effect on interstate commerce due to rates charged by this short line railroad operating entirely within Texas state borders. He further pointed out inconsistencies in ICC’s approach, as it did not attempt to control all similar situations across different states but only targeted specific cases arbitrarily which he believed could lead to unjust results and abuses of authority.