In the case of Eichholz v. Public Service Commission of Missouri et al., 1938, the U.S Supreme Court ruled in favor of the Public Service Commission. The dispute arose when Eichholz, a private carrier operating under contract with a single shipper, was denied an application to become a common carrier by the Missouri commission on grounds that public convenience and necessity did not require such service. The court held that there was no violation of due process or equal protection clauses as claimed by Eichholz because state regulatory power over local aspects of interstate commerce is valid until Congress decides otherwise. Furthermore, it stated that judicial review does not extend to reweighing evidence presented before administrative bodies like commissions but only checks if their decisions are supported by substantial evidence.

In the dissenting opinion for Eichholz v. Public Service Commission of Missouri, Justice Black argued that the majority's decision violated principles of federalism by allowing a state agency to regulate interstate commerce, which is constitutionally reserved for Congress. He contended that the case involved an issue of interstate commerce because it concerned rates charged by a company operating in multiple states and therefore should have been under federal jurisdiction. Furthermore, he disagreed with the majority's interpretation of "direct" versus "indirect" effects on interstate commerce as being too narrow and inconsistent with previous court rulings. In his view, any action affecting rates would inevitably impact interstate trade directly or indirectly and thus fall within congressional power to regulate.