The Supreme Court case In re Pennsylvania Company, Petitioner (1890) revolved around the issue of whether a federal court could order a corporation to produce books and papers for an investigation in another jurisdiction. The Pennsylvania Company was subpoenaed by a New York court to provide certain documents related to an ongoing legal dispute there. However, the company argued that since it was incorporated in Pennsylvania and not doing business in New York, it should not be subject to its courts' jurisdiction. The U.S. Supreme Court disagreed with this argument and ruled that corporations were indeed required to comply with such orders if they had sufficient contact with the other state - which the Pennsylvania Company did through its railroad operations running into New York State.

The dissenting opinion in the case of In re Pennsylvania Company, 1890, argued that the court's decision to uphold an injunction against a railroad company was incorrect. The dissenting justices believed that the majority had overstepped its bounds by intervening in what they saw as a private dispute between two corporations. They contended that it was not within their jurisdiction to decide on matters related to corporate governance and management decisions unless there were clear violations of law or rights involved. Furthermore, they expressed concerns about setting a dangerous precedent where courts could interfere with business operations based on subjective interpretations of "public interest". This, according to them, could potentially lead to judicial overreach and undermine economic freedom and enterprise autonomy.