In the case of Delaware, Lackawanna & Western Railroad Company v. United States (1918), the U.S. Supreme Court was asked to determine whether a railroad company could be held liable for damages incurred during interstate commerce transportation under the Carmack Amendment to the Interstate Commerce Act of 1906. The plaintiff, Delaware, Lackawanna & Western Railroad Company argued that it should not be held responsible as it had issued a through bill of lading which included routes operated by other carriers and thus responsibility should lie with them. However, in its decision, the court ruled against this argument stating that according to provisions within the Carmack Amendment any initial carrier issuing such a bill would remain liable for any damage or loss occurring throughout entire transit even if parts were handled by different carriers unless specifically released from liability by shipper agreement.

In the dissenting opinion for Delaware, Lackawanna & Western Railroad Company v. United States (1918), Justice McReynolds expressed concern over the majority's interpretation of the Hepburn Act. He argued that it was not Congress' intention to give such broad power to the Interstate Commerce Commission (ICC) in regulating railroad rates and practices. The justice believed that this decision would allow ICC to interfere with private contracts between railroads and coal companies, which he saw as an infringement on their rights. Furthermore, he warned against potential abuse of authority by administrative bodies like ICC if they were given too much discretion without clear legislative guidelines or judicial oversight.