In the Luxton v. North River Bridge Company case of 1893, the U.S Supreme Court ruled in favor of the North River Bridge Company. The plaintiff, Luxton, had argued that a toll bridge built by the company over Hudson river between New York and New Jersey was unconstitutional as it interfered with interstate commerce. However, Congress had authorized construction of this bridge under an act passed in 1890 which also allowed for collection of tolls to recover costs incurred during its building process. The court held that since Congress has authority over interstate commerce and they approved this project including its funding mechanism (tolls), it did not violate any constitutional provisions regarding interference with such commerce. Therefore, Luxton's claim was dismissed.

In the dissenting opinion for Luxton v. North River Bridge Company, it was argued that the Supreme Court did not have jurisdiction over this case as there was no controversy between states or citizens of different states. The dissent emphasized that Luxton, a citizen of New York, had brought suit against the North River Bridge Company in a state court and lost; he then appealed to federal courts on grounds unrelated to interstate matters. It was further noted that while Congress has power under the Constitution's Commerce Clause to regulate bridges across navigable waters, such regulation does not automatically confer federal jurisdiction over all disputes involving those structures. Therefore, according to this view, Luxton’s appeal should be dismissed for lack of jurisdiction rather than decided on its merits.