In the case of Louisville & Nashville Railroad Company v. Ohio Valley Tie Company in 1916, the Supreme Court ruled on a dispute involving freight charges. The Ohio Valley Tie Company had shipped lumber over the Louisville & Nashville Railroad and was charged based on a tariff filed with the Interstate Commerce Commission (ICC). However, they argued that they should have been charged at a lower rate according to an earlier contract with another railroad company which had since been acquired by Louisville & Nashville. The court held that once tariffs are filed with ICC, it becomes binding for both parties and cannot be altered by private contracts or agreements made prior to its filing unless changed through proper channels provided under law. Therefore, despite their previous agreement for lower rates, Ohio Valley was required to pay freight charges as per current tariff filed with ICC.

In the dissenting opinion for Louisville & Nashville Railroad Company v. Ohio Valley Tie Company, Justice Holmes disagreed with the majority's interpretation of a contract between two private entities and its implications on interstate commerce regulation. He argued that while Congress has power over interstate commerce, it does not mean they have control over all contracts affecting such commerce. The case involved a dispute about freight rates in a contract between the railroad company and tie company; however, Holmes believed this was an issue to be settled by state law rather than federal jurisdiction because it did not directly impede or obstruct interstate trade but merely influenced economic conditions under which such trade occurred. Therefore, he contended that applying federal authority in this context would excessively broaden its scope beyond constitutional limits.