In the 1903 case Northern Securities Company v. United States, the Supreme Court upheld a ruling that dissolved the Northern Securities Company for violating antitrust laws. The company was formed by powerful railroad magnates who sought to establish a monopoly over rail transportation in much of the western U.S., which led President Theodore Roosevelt's administration to sue under the Sherman Antitrust Act. The court ruled 5-4 against Northern Securities, arguing that it had indeed violated federal law by attempting to monopolize interstate commerce. This decision marked one of the first times that antitrust legislation was used successfully against a major corporation and set an important precedent for future cases involving business regulation.

In the dissenting opinion for Northern Securities Company v. United States, Justice Edward D. White argued that the majority's interpretation of the Sherman Antitrust Act was too broad and could potentially criminalize normal business practices. He contended that not all combinations or mergers were inherently harmful to competition and should not be automatically deemed illegal under antitrust laws. Instead, he suggested a more nuanced approach where only those combinations designed with an intent to monopolize would violate the law. Furthermore, he disagreed with the majority’s view on interstate commerce regulation, arguing it overstepped federal authority by interfering in matters reserved for individual states' jurisdiction under constitutional principles of federalism.