In the case of L.P. Steuart & Bro., Inc. v. Bowles, Price Administrator, et al., 1943, the U.S Supreme Court dealt with issues related to price control during World War II under the Emergency Price Control Act of 1942 (EPCA). The petitioner, L.P Steuart & Bro., a wholesale fuel oil distributor in Washington D.C was charged by Chester Bowles, then Price Administrator for violating maximum price regulations set by EPCA when it sold fuel oil at prices higher than those permitted by law. The defense argued that their pricing was justified as they were merely passing on increased costs from suppliers and transportation charges which had risen due to war conditions - an argument known as "pass-on defense". However, this contention was rejected both in lower courts and finally in Supreme Court ruling that such interpretation would undermine the purpose of EPCA i.e., controlling inflation during wartime economy. It held that allowing pass-through cost increases would result in a cascading effect leading to uncontrollable inflationary spiral contrary to legislative intent behind EPCA.

In the dissenting opinion for L. P. Steuart & Bro., Inc. v. Bowles, Price Administrator, et al., Justice Owen Roberts argued that the majority's decision to uphold price controls on poultry violated principles of federalism and exceeded Congress' power under the Commerce Clause of the Constitution. He contended that while Congress has broad authority to regulate interstate commerce, it does not have unlimited power to control prices within individual states or intrastate transactions which do not directly affect interstate commerce as a whole - such as local sales of poultry in this case - without clear evidence showing its impact on national economy or war effort during World War II period when this case was decided upon by Supreme Court in 1943.