In the 1950 case of Missouri ex rel. Southern Railway Co. v. Mayfield, the Supreme Court of the United States ruled in favor of Southern Railway Company against Judge Mayfield who had issued an injunction preventing them from removing a steam locomotive from their property for repair work without his permission. The court held that this was an abuse of judicial power as it interfered with interstate commerce and violated federal law which grants railroads broad discretion to manage their own equipment and operations without undue interference by state courts or officials. This decision reaffirmed the supremacy of federal law over state laws in matters related to interstate commerce, particularly where railroad operations are concerned.

In the dissenting opinion for Missouri ex rel. Southern Railway Co. v. Mayfield, Justice Frankfurter argued that the majority's decision to overturn a state court ruling was inappropriate and overstepped federal authority. He contended that it is not within the Supreme Court's jurisdiction to correct errors made by state courts in interpreting their own laws unless there is an infringement on federal law or constitutional rights, which he did not believe was present in this case. Furthermore, he expressed concern about setting a precedent where the Supreme Court becomes an appellate court for all cases involving railroad companies under state law due to its interpretation of Congress' intent behind certain legislation related to railroads and interstate commerce.