In the case of Northern Ohio Traction & Light Company et al. v. State of Ohio on the Relation of Pontius, 1917, the Supreme Court dealt with a dispute over whether an electric company had to pay for street repairs caused by its operations in Canton, Ohio. The city argued that under state law and their franchise agreement with the company, they were responsible for such costs. However, Northern Ohio Traction & Light Company contended that this requirement was unconstitutional as it violated their Fourteenth Amendment rights to due process and equal protection under law because other utilities weren't required to bear similar expenses. The court ruled against them stating that there was no constitutional violation since these obligations were part of their original contract with the city which they voluntarily accepted.

In the dissenting opinion for Northern Ohio Traction & Light Company et al. v. State of Ohio on the Relation of Pontius, Justice Holmes argued that while a state has the power to regulate public utilities, it does not have unlimited authority in this regard. He contended that there must be reasonable grounds for such regulation and intervention by the state should only occur when necessary to protect public interests or prevent abuse of monopoly powers. In this case, he believed that there was no evidence presented showing any misuse or mismanagement by Northern Ohio Traction & Light Company which would justify interference from the state government in its operations and management decisions.