In the case of Ex Parte in the Matter of Lincoln Gas & Electric Light Company, 1920, the petitioner was a public utility company that sought to increase its rates. The Nebraska State Railway Commission denied this request and ordered it to continue with its existing rates. The company argued that such an order violated their constitutional rights under the Fourteenth Amendment as it deprived them of property without due process and denied them equal protection under law. However, upon appeal, the U.S Supreme Court ruled against Lincoln Gas & Electric Light Company stating that there was no violation of constitutional rights because they were not being deprived unfairly or unreasonably by having to maintain their current rates.

In the dissenting opinion for Ex Parte in the Matter of Lincoln Gas & Electric Light Company, 1920, it was argued that the court erred by not considering whether or not there were other remedies available to Lincoln Gas before resorting to bankruptcy proceedings. The dissent emphasized that a corporation should only be allowed to file for bankruptcy if it is insolvent and has exhausted all other options. In this case, however, they believed that Lincoln Gas had failed to demonstrate insolvency and did not show any evidence of having pursued alternative solutions prior to filing for bankruptcy. Therefore, according to the dissenters' view, allowing such an action would set a dangerous precedent where corporations could use bankruptcy as an easy way out instead of responsibly addressing their financial difficulties.