In the Missouri, Kansas and Texas Railway Company v. United States case of 1914, the Supreme Court ruled that a railway company could not charge more for a shorter distance than it did for a longer one on its line unless expressly authorized by the Interstate Commerce Commission (ICC). The court upheld an order from ICC which required railroads to cease charging higher rates per mile for short hauls than they charged per mile for long hauls over the same line in the same direction. This decision was based on Section 4 of the Interstate Commerce Act, also known as "the long and short haul clause". It marked an important step towards regulating railroad companies' pricing policies and preventing them from exploiting their monopoly power at customers' expense.

In the dissenting opinion for the Missouri, Kansas and Texas Railway Company v. United States case in 1914, Justice Holmes argued that the Interstate Commerce Commission (ICC) did not have authority to impose its decision on a railroad company regarding which route it should use for shipping goods. He believed that this was an overreach of power by ICC as it interfered with business operations without sufficient justification or evidence of wrongdoing. Furthermore, he contended that such decisions could potentially disrupt commerce rather than regulate it fairly and effectively. This view emphasized a more laissez-faire approach to economic regulation where businesses are allowed greater freedom in their operational choices unless there is clear proof of harm or violation of laws.