In the 1914 case of Great Northern Railway Company v. State of Minnesota Ex Rel. State Railroad & Warehouse Commission, the U.S. Supreme Court ruled in favor of the railway company, overturning a decision by Minnesota's state courts that had upheld an order from its railroad commission requiring railroads to install safety appliances on their cars and engines beyond what was mandated by federal law. The court held that this requirement was preempted by federal law under the Safety Appliance Act (SAA) which set uniform national standards for such equipment on interstate trains to ensure safety and efficiency in operations across state lines. Therefore, individual states could not impose additional or different requirements than those specified in SAA as it would interfere with interstate commerce regulation - a power reserved exclusively for Congress under Constitution's Commerce Clause.

In the dissenting opinion for Great Northern Railway Company v. State of Minnesota, Justice Holmes argued that the state had a right to regulate railroad rates within its borders and that it was not an infringement on interstate commerce. He contended that there is no constitutional principle preventing states from regulating businesses operating within their jurisdiction, even if those businesses also operate across state lines. The majority's decision, he believed, would undermine states' abilities to protect their citizens from unfair business practices by large corporations like railroads. Furthermore, he disagreed with the majority's interpretation of previous court decisions regarding similar issues and felt they were misapplying them in this case.