In the 1905 case of Interstate Commerce Commission v. The Lake Shore and Michigan Southern Railway Company, the U.S. Supreme Court ruled in favor of the railway company, asserting that it was not within the jurisdiction of the Interstate Commerce Commission (ICC) to mandate a specific rate for rail transportation services. This decision came after an investigation by ICC into alleged unreasonable rates charged by several railroad companies including The Lake Shore and Michigan Southern Railway Company. While acknowledging that ICC had authority to determine whether existing rates were reasonable or discriminatory under federal law, Justice Rufus W. Peckham clarified that this did not extend to setting new rates; such power would be legislative in nature rather than regulatory or judicial.

The dissenting opinion in the case of Interstate Commerce Commission v. The Lake Shore and Michigan Southern Railway Company et al., 1905, argued that the majority's decision undermined the power of Congress to regulate interstate commerce. It contended that by invalidating a law passed by Congress to prevent discriminatory pricing practices among railroads, the court was overstepping its bounds and encroaching on legislative authority. This view held that it is not within judicial purview to question or undermine Congressional decisions regarding what constitutes reasonable rates or fair business practices in interstate commerce; such matters should be left entirely up to lawmakers' discretion as they are better equipped with resources for comprehensive investigation and deliberation on these complex issues. Furthermore, this perspective emphasized that courts should defer more heavily towards Congressional judgment unless there is clear violation of constitutional rights involved.