The U.S. Supreme Court case Gray, Director of the Bituminous Coal Division of the Department of Interior, et al. v. Powell et al., Receiver (1941) revolved around a dispute over coal royalties under the Bituminous Coal Act 1937 and its amendments in 1939. The plaintiffs were receivers for two bankrupt coal companies who had failed to pay their royalty fees as required by law, while defendants included officials from the Department of Interior's Bituminous Coal Division tasked with collecting these payments. The main issue was whether or not these unpaid royalties could be collected after bankruptcy proceedings had begun but before they were completed - essentially asking if such debts should be considered administrative expenses that must be paid off first during bankruptcy liquidation process or general unsecured claims which are often left unpaid due to lack of funds. The court ruled in favor of defendants stating that such royalty obligations did indeed qualify as administrative expenses because they arose out of actions taken by trustees during bankruptcy proceedings (i.e., continued operation and sale of mines). Therefore, they should receive priority payment over other creditors' claims.

In the dissenting opinion for Gray v. Powell, Justice Roberts argued that the majority's decision to uphold a federal law allowing coal producers to set minimum prices was unconstitutional. He believed that this power should be reserved for states under their police powers and not given to private entities such as coal companies. Furthermore, he contended that Congress had overstepped its bounds by delegating legislative authority to these private groups without providing any standards or guidelines on how they should exercise this power. This lack of oversight could potentially lead to arbitrary and discriminatory practices in setting coal prices which would harm consumers and violate principles of fair competition. Thus, while recognizing the need for government intervention during times of economic crisis, Justice Roberts maintained that such measures must still adhere strictly within constitutional limits.