In the 1906 case of Mississippi Railroad Commission v. Illinois Central Railroad Company, the U.S Supreme Court ruled in favor of the Illinois Central Railroad Company. The dispute arose when the Mississippi Railroad Commission ordered a reduction in intrastate freight rates which was challenged by Illinois Central as being unjust and unreasonable. The company argued that such reductions would lead to revenue loss and potentially bankruptcy, thereby violating their constitutional rights under Fourteenth Amendment's due process clause. Upon review, it was found that there was no substantial evidence provided by the commission demonstrating that existing rates were excessive or discriminatory against local trade compared to interstate commerce. Therefore, without sufficient proof showing these rates were unfair or prejudicial towards intrastate business activities, they could not be deemed unreasonable nor unconstitutional by law. Thusly ruling out any violation of due process rights for Illinois Central.

In the dissenting opinion for Mississippi Railroad Commission v. Illinois Central Railroad Company, Justice Harlan argued that the state of Mississippi had a legitimate interest in regulating railroad rates within its borders to protect its citizens from excessive charges. He contended that states should have the power to regulate commerce within their boundaries as long as they do not interfere with interstate commerce or violate federal law. Harlan disagreed with the majority's view that only Congress could regulate such matters, arguing this interpretation undermined states' rights and powers granted by the Constitution. Furthermore, he expressed concern about potential abuses if corporations were left unchecked without state regulation.