In the 1923 case of State of Missouri on the Relation of Barrett, Attorney General, et al. v. Kansas Natural Gas Company, the Supreme Court ruled in favor of Kansas Natural Gas Company (KNGC). The state of Missouri had attempted to regulate and limit KNGC's exportation rates for natural gas from within its borders to other states. However, this was found by the court to be a violation against interstate commerce laws as it interfered with free trade between states. The ruling established that only federal authorities have jurisdiction over such matters under the Commerce Clause in Article I Section 8 Clause 3 of U.S Constitution which gives Congress power “to regulate commerce with foreign nations and among several States.” Therefore, individual states cannot impose restrictions or regulations on companies exporting goods or services across state lines.

In the dissenting opinion for the case of State of Missouri on the Relation of Barrett, Attorney General, et al. v. Kansas Natural Gas Company (1923), Justice Oliver Wendell Holmes Jr., joined by Justices Louis Brandeis and Harlan Fiske Stone, argued that states should have regulatory power over natural gas companies operating within their borders. They contended that a state's authority to control its own resources should not be undermined by an overly broad interpretation of the Commerce Clause in favor of federal jurisdiction. The dissenters believed that if a company operates within a state and uses its resources, it is subject to regulation by that state regardless if it also engages in interstate commerce or not. They warned against allowing corporations to evade local regulations simply because they operate across multiple states.