The Northern Securities Company v. United States case in 1903 was a landmark Supreme Court decision that strengthened federal power to regulate big businesses, particularly railroads. The Northern Securities Company, a large railroad trust formed by E.H. Harriman, James J. Hill and J.P Morgan, controlled the majority of railway lines from Chicago to the Pacific Northwest which led to monopolistic practices detrimental to competition and free trade. The U.S government sued under the Sherman Antitrust Act arguing that this consolidation obstructed interstate commerce. In a 5-4 decision favoring the government's position, it marked one of President Theodore Roosevelt’s major victories against trusts during his presidency and set an important precedent for future antitrust cases.

In the dissenting opinion for Northern Securities Company v. United States, Justice Edward Douglas White argued that the majority's interpretation of the Sherman Antitrust Act was too broad and could potentially stifle legitimate business operations. He contended that not all combinations or mergers should be considered as restraints on trade; only those specifically intended to monopolize or restrain commerce should fall under this category. Furthermore, he believed that a literal reading of the law would lead to absurd results because it would make illegal any contract which directly affected interstate commerce, regardless of its nature or purpose. He also expressed concern about federal overreach into areas traditionally regulated by states and warned against judicial activism in interpreting laws based on perceived societal needs rather than strict statutory construction.