In the case of Marion & Rye Valley Railway Company v. United States, 1925, the Supreme Court ruled on whether a railway company was entitled to compensation for land taken by the government under eminent domain laws. The Marion & Rye Valley Railway Company claimed that it should be compensated for its right-of-way over public lands granted by Congress in 1906, which were later reclaimed by the federal government during World War I to build a dam and reservoir as part of war efforts. The court held that since these rights were revocable at will by Congress without payment of compensation, there was no taking within the meaning of Fifth Amendment's Takings Clause when such rights are revoked or terminated. Therefore, no compensation was due to Marion & Rye Valley Railway Company from U.S Government.

In the dissenting opinion for Marion & Rye Valley Railway Company v. United States, it was argued that the Interstate Commerce Commission (ICC) had overstepped its authority by ordering a railway company to construct and maintain an unprofitable line of track. The dissenting justices believed that this order violated the Fifth Amendment's protection against taking private property for public use without just compensation. They contended that while Congress has broad powers to regulate interstate commerce, these powers do not extend to forcing a private entity into financial loss through compulsory service obligations. Furthermore, they asserted that if such orders were allowed to stand, it could set a dangerous precedent where businesses are forced into bankruptcy due to regulatory demands from government agencies.