In the case of Minneapolis and St. Louis Railroad Company v. State of Minnesota, 1903, the U.S Supreme Court ruled in favor of the state's right to regulate railroad rates within its borders. The Minneapolis and St. Louis Railroad Company had challenged a law passed by Minnesota that set maximum freight charges for railroads operating within the state, arguing it violated their constitutional rights under both due process and equal protection clauses as well as interfering with interstate commerce regulation which they claimed was solely federal jurisdiction. However, Justice Edward D White delivered an opinion stating that while states cannot interfere with interstate commerce directly or indirectly through legislation affecting only intrastate trade aspects; such laws are not unconstitutional if they do not conflict with any act of Congress regulating such commerce nor infringe upon powers exclusively vested in national government.

In the dissenting opinion for Minneapolis and St. Louis Railroad Company v. State of Minnesota, Justice Harlan argued that the court's decision undermined states' rights to regulate businesses within their borders. He contended that railroads were public highways, subject to state control in matters such as rate-setting, even if they engaged in interstate commerce. The majority's ruling would effectively strip states of this power and place it solely with Congress - a move he viewed as unconstitutional given the Tenth Amendment’s reservation of powers not delegated to the federal government for individual states or people. Furthermore, he warned against judicial overreach into legislative territory by determining what constituted "reasonable" rates rather than leaving it up to lawmakers who are more equipped with knowledge about local conditions and needs.