In the 1922 case of Joslin Manufacturing Company v. City of Providence, the U.S. Supreme Court ruled in favor of the city and upheld its right to enforce zoning regulations on a privately owned property. The plaintiff, Joslin Manufacturing Company, argued that these regulations infringed upon their constitutional rights by limiting how they could use their own land for industrial purposes. However, the court found that such restrictions were within a municipality's power as long as they served public health or safety interests and did not constitute an arbitrary exercise of authority. This decision affirmed local governments' ability to regulate land use through zoning laws without violating private property owners' constitutional rights.

In the dissenting opinion for Joslin Manufacturing Company v. City of Providence, Justice Holmes disagreed with the majority's ruling that upheld a city ordinance prohibiting manufacturing operations after 6 p.m., which was challenged by Joslin Manufacturing as an infringement on its property rights. Holmes argued that while it is within a city’s power to regulate businesses for public welfare, this particular regulation seemed arbitrary and without substantial justification in terms of health or safety concerns. He contended that such restrictions should only be imposed when there are clear reasons related to public good, not merely because some people might find nighttime factory operations inconvenient or unpleasant. The justice believed this case represented an overreach of government authority into private business affairs without sufficient cause.