The U.S. Supreme Court case Federal Power Commission v. Niagara Mohawk Power Corp., 1953, revolved around the issue of whether or not the Federal Power Commission (FPC) had jurisdiction to regulate sales of electricity by a private utility company, Niagara Mohawk Power Corporation, to a municipal corporation for resale. The FPC argued that it did have such authority under Section 201(b) of the Federal Power Act which grants it regulatory power over electric energy in interstate commerce and sale at wholesale rates. However, Niagara Mohawk contended that this section only applied to direct sales for consumption and not resales by municipalities. In its decision, the Supreme Court sided with FPC stating that Congress intended broad federal regulation when they enacted Section 201(b). Therefore, even though there was an indirect relationship between Niagara Mohawk's wholesale transactions and out-of-state consumers due to municipal reselling activities; these transactions still fell within interstate commerce subjecting them under FPC’s jurisdiction.

In the dissenting opinion for Federal Power Commission v. Niagara Mohawk Power Corp., Justice Jackson, joined by Justices Frankfurter and Burton, argued that the majority's decision to uphold the Federal Power Commission's (FPC) order was a misinterpretation of both legislative intent and statutory language. He contended that Congress did not intend for FPC to regulate power companies' sales of electricity generated at non-federally licensed facilities when it passed the Federal Power Act. Furthermore, he asserted that such an interpretation would give FPC an unprecedented level of control over private industry without clear congressional authorization. The dissent also expressed concern about potential negative impacts on state regulatory authority and economic stability in the energy sector if FPC were allowed to extend its jurisdiction in this manner.