In the 1912 case Houghton, Receiver v. Burden, the United States Supreme Court ruled on a dispute involving railroad freight rates. The plaintiff was a receiver for a bankrupt railroad company who sued to recover overcharges made by another railway company under an agreement that had been approved by the Interstate Commerce Commission (ICC). The defendant argued that they were entitled to charge higher rates because of their superior facilities and services. However, the court held that once rates have been established and agreed upon through proper channels such as ICC approval, any deviation from those set prices constitutes discrimination in violation of federal law. Therefore, it was decided in favor of Houghton with justices ruling unanimously against Burden's claim.

In the dissenting opinion for Houghton v. Burden, it was argued that the majority's decision to uphold a Kansas law allowing receivers of insolvent banks to recover double damages from stockholders who had received dividends while the bank was insolvent went against established principles of corporate law. The dissent contended that this ruling unfairly penalized innocent shareholders who may not have been aware of their bank’s insolvency when they received dividends and were unable to return them once they became aware. Furthermore, it was pointed out that such a punitive measure could discourage investment in banking institutions due to increased risk, which would be detrimental for economic growth and stability. It also raised concerns about potential abuse by receivers seeking personal gain at the expense of unsuspecting shareholders.