The U.S. Supreme Court case Missouri Pacific Railway Company v. State of Kansas Ex Rel. Railroad Commissioners in 1909 revolved around the issue of whether a state has the authority to regulate railroad rates within its borders, even if it affects interstate commerce indirectly. The Missouri Pacific Railway Company challenged an order by the Kansas Railroad Commissioners that reduced intrastate freight rates, arguing that it interfered with interstate commerce and violated their constitutional rights under the Fourteenth Amendment's due process clause because they were not given a fair hearing before implementing rate changes. However, the Supreme Court upheld Kansas' right to regulate railway rates within its jurisdiction as long as there was no direct interference with interstate trade or violation of federal law on this matter. Furthermore, regarding due process concerns raised by Missouri Pacific Railway Co., Justice Day stated that while corporations are entitled to procedural fairness when their property is at stake, these protections do not extend so far as requiring judicial review prior to every administrative decision affecting them.

In the dissenting opinion for Missouri Pacific Railway Company v. State of Kansas, Justice Harlan argued that the majority's decision was an overreach of federal power and a violation of states' rights. He contended that railroads were public highways, subject to state regulation as long as it did not interfere with interstate commerce or violate any specific provision in federal law. The justice believed that the court had no right to intervene unless there was clear evidence showing such interference or violation. Furthermore, he emphasized that courts should be cautious when dealing with matters related to local affairs and business operations within individual states because they are better handled by state authorities who have more knowledge about local conditions and needs than distant federal judges do.