The U.S. Supreme Court case Michaelson et al. v. United States ex rel. Chicago, St Paul, Minneapolis & Omaha Railway Company in 1924 revolved around the issue of whether a federal court could require a defendant to post bail as security for costs in an equity suit brought by the United States on behalf of a private party (the railway company). The defendants were landowners who had been sued by the government on behalf of the railway company over alleged violations of certain railroad rights-of-way across their lands. They argued that requiring them to post bail violated their constitutional right against excessive fines and penalties under Eighth Amendment. However, the Supreme Court ruled against them stating that such requirement did not constitute punishment or penalty but was merely intended to ensure payment of litigation expenses should they lose at trial; thus it didn't violate any constitutional protections afforded by Eighth Amendment.

In the dissenting opinion for Michaelson et al. v. United States ex rel. Chicago, St. Paul, Minneapolis & Omaha Railway Company, Justice Holmes argued that the majority's decision to uphold a contempt of court charge against striking railroad workers was unjustified and overly punitive in nature. He contended that the strike did not constitute an obstruction of justice as it did not directly interfere with any ongoing legal proceedings or judicial orders at the time it took place; rather, he saw it as a labor dispute between private parties which should be resolved through negotiation and compromise instead of criminal prosecution. Furthermore, he criticized his colleagues' broad interpretation of "contempt" under federal law and warned about potential abuses if such expansive powers were left unchecked by higher courts or legislative bodies in future cases involving similar circumstances.