In the case of Federal Trade Commission v. Klesner, the Supreme Court in 1929 ruled on whether or not an order by the Federal Trade Commission (FTC) could be enforced against a corporation that had already dissolved before the order was issued. The FTC had found that Klesner's company, United States Distributing Corporation, was engaging in unfair and deceptive trade practices and sought to enforce an order prohibiting these actions. However, by this time, Klesner’s corporation had been voluntarily dissolved under state law. The court held that since there is no provision within federal law allowing for enforcement orders against non-existent entities such as a dissolved corporation; therefore it cannot enforce its cease-and-desist order against United States Distributing Corporation after its dissolution.

In the dissenting opinion for Federal Trade Commission v. Klesner, Justice Stone argued that the majority's decision to limit the powers of administrative agencies was misguided. He believed that Congress had intended for these agencies to have broad authority in order to effectively regulate commerce and protect consumers from unfair business practices. The majority's interpretation, he contended, would undermine this purpose by restricting their ability to act on certain types of complaints or evidence. Furthermore, he disagreed with the notion that courts should be able to review and overturn agency decisions simply because they disagree with them; instead, he felt judicial review should only occur if there is a clear error or abuse of power. Overall, Justice Stone feared that this ruling could set a dangerous precedent by weakening regulatory bodies and hindering their ability to enforce federal laws.