The U.S. Supreme Court case Mayo, Commissioner of Agriculture of Florida, et al. v. Lakeland Highlands Canning Co., et al., 1939 revolved around a dispute over the constitutionality of a Florida statute that imposed fees on citrus fruit growers for advertising and marketing their products outside the state. The plaintiffs, including Lakeland Highlands Canning Co., argued that this law was unconstitutional as it violated the Commerce Clause by burdening interstate commerce and discriminating against out-of-state buyers. However, the Supreme Court ruled in favor of Mayo (the Commissioner), upholding the validity of such laws under states' rights to regulate local industries for public benefit even if they indirectly affect interstate commerce.

In the dissenting opinion for Mayo, Commissioner of Agriculture of Florida, et al. v. Lakeland Highlands Canning Co. et al., Justice Black argued that the majority's decision to strike down a Florida law regulating citrus canning was incorrect and overstepped their judicial authority. He contended that it is not within the purview of courts to decide whether or not a state regulation is wise or unwise; rather, they should only determine its constitutionality under due process clause considerations. In his view, this particular legislation did not violate any constitutional rights as it aimed at preventing potential fraud in commerce by ensuring uniformity in canned products' quality and weight - an objective he deemed legitimate for public welfare protection purposes.