The U.S. Supreme Court case Interstate Commerce Commission v. Chicago, Burlington and Quincy Railroad Company in 1901 revolved around the issue of whether the Interstate Commerce Commission (ICC) had the authority to set reasonable rates for railroad companies. The ICC argued that it was within its power to determine what constituted a "reasonable" rate, while the Chicago, Burlington and Quincy Railroad Company contended that this was an overreach of authority by a regulatory body. The court ruled in favor of the railroad company stating that while Congress could regulate commerce, it did not have unlimited powers to do so under the Constitution's Commerce Clause; hence ICC cannot fix railway rates unless they are unreasonable or discriminatory. This decision limited ICC's power and marked a significant moment in American administrative law as it established judicial review over administrative actions on substantive grounds.

In the dissenting opinion for Interstate Commerce Commission v. Chicago, Burlington and Quincy Railroad Company, Justice Harlan argued that the majority's decision undermined the authority of the Interstate Commerce Commission (ICC). He contended that Congress had established ICC to regulate railroads in response to public demand for protection against perceived abuses by these corporations. The court’s ruling effectively stripped ICC of its power to determine reasonable rates or practices, which was contrary to congressional intent. Furthermore, he disagreed with the majority's interpretation of "reasonableness" as a judicial rather than administrative question; this view would require courts - not an expert agency like ICC -  to decide on complex matters related to railroad operations and economics. In essence, Justice Harlan believed that this case represented a significant setback in efforts towards effective regulation of interstate commerce.