In the Northwestern Fuel Company v. Brock case of 1890, the U.S Supreme Court ruled in favor of Northwestern Fuel Company. The dispute arose when Brock sued for damages after his land was flooded due to a dam constructed by the fuel company on a river adjacent to his property. He claimed that this action constituted an infringement upon his riparian rights as he could no longer use the water from the river for irrigation purposes and it also caused damage to his land through flooding. However, according to Minnesota law at that time, any person or corporation had legal right to construct dams or other obstructions across navigable rivers if they did not interfere with navigation and were beneficial for public utility like facilitating transportation of logs downstream which was done by Northwestern Fuel Co.. The court held that since there was no interference with navigation and because state law permitted such actions, Brock's claim lacked merit.

In the dissenting opinion for Northwestern Fuel Company v. Brock, the justice argued that a contract made in one state should not be voided by another state's laws if it does not violate any federal law or policy. The case involved a Minnesota statute that prohibited contracts which restricted coal dealers from selling other brands of coal than those specified in their agreements with mining companies. The justice believed this was an interference with interstate commerce and thus unconstitutional under the Commerce Clause of the U.S Constitution. He also contended that such statutes were detrimental to business as they prevented companies from making advantageous arrangements and undermined contractual freedom. Furthermore, he disagreed with majority’s view on public interest stating there was no evidence showing these exclusive contracts harmed consumers or created monopolies.