In the case of Leach, doing business as Organo Product Company v. Carlile, Postmaster in 1921, the Supreme Court ruled on a dispute involving mail fraud and false advertising. The plaintiff (Leach) was accused by the defendant (Carlile) of using deceptive practices to sell his products through mail order. The postmaster general had issued a fraud order that barred Leach from receiving any further mails related to his business due to these allegations. In response, Leach filed suit against Carlile claiming that he did not receive adequate notice or opportunity for hearing before this action was taken and thus it violated his Fifth Amendment rights. The court sided with Carlile ruling that while an individual does have right to notice and hearing under normal circumstances; however when there is clear evidence of fraudulent activity which could potentially harm public interest if allowed to continue unchecked - such as misleading advertisements - then immediate action can be justified without prior notification or hearing.

In the dissenting opinion for Leach v. Carlile, Justice Holmes argued that the Postmaster General's decision to deny mail privileges to a business based on his belief that it was conducting fraudulent activities should not be subject to judicial review. He contended that Congress had granted this authority solely to the Postmaster General and courts did not have jurisdiction over such matters. Furthermore, he believed there were sufficient safeguards in place as businesses could appeal any adverse decisions made by the Postmaster General within his department before resorting to legal action in court. Thus, according to Justice Holmes' view, if a business is dissatisfied with an administrative ruling from a government agency like the postal service, its remedy lies within appealing through administrative channels rather than seeking intervention from judiciary bodies.