In the case of The People of the State of Illinois, on the Relation of Dunne, Governor, and Lucey, Attorney General v. Economy Light and Power Company (1913), the Supreme Court dealt with issues related to public utilities regulation. The state government sought to enforce a law that required public utility companies to obtain certificates from a state commission before issuing stocks or bonds. This was challenged by Economy Light and Power Company who argued that this requirement violated their rights under both federal and state constitutions as it interfered with interstate commerce and deprived them of property without due process. However, the Supreme Court upheld Illinois' right to regulate its own utilities in order to protect consumers from potential abuses such as overcharging or poor service quality by these companies. It ruled that states have broad powers under their police power authority for regulating businesses within their borders which serve a public interest like utilities do.

The dissenting opinion in the case of The People of the State of Illinois v. Economy Light and Power Company argued that the majority's decision to uphold a state law allowing for public control over utilities was an infringement on private property rights. They contended that such laws were unconstitutional, as they violated principles of due process by not providing adequate compensation for seized assets. Furthermore, they believed it was inappropriate for courts to intervene in economic matters best left to legislative bodies or market forces. This perspective emphasized a strict interpretation of constitutional protections against government interference with private enterprise and expressed concern about potential abuses stemming from unchecked governmental power over industry.