In the case of In re Rapier, 1891, the U.S. Supreme Court ruled that Congress had the power to regulate and prohibit certain types of mail under its constitutional authority to establish post offices and postal roads. The petitioner, Mr. Rapier was charged with sending lottery tickets through mail which was prohibited by an act passed by Congress in 1890 known as "An Act for Suppression of Lottery Traffic through National and International Commerce". He challenged this law arguing it exceeded Congressional powers granted by Constitution's Postal Clause (Article I, Section 8). However, his argument was rejected by both lower courts and ultimately Supreme Court too upheld these rulings stating that while Constitution does not explicitly grant Congress power to exclude items from mails but such a power is implied given their responsibility over postal system. This decision reinforced federal government's ability to regulate commerce via postal service.

In the dissenting opinion for In re Rapier, it was argued that Congress does not have the power to regulate all matters related to interstate commerce. The dissenting justices believed that while Congress has broad powers under the Commerce Clause of the Constitution, these powers are not unlimited. They contended that prohibiting lottery tickets from being sent through mail is a form of police power reserved for individual states and is beyond federal jurisdiction. This view held that such regulation would infrally upon state rights and disrupt balance between federal and state governments as established by U.S constitution. Therefore, they disagreed with majority's interpretation of Commerce Clause in this case.