The U.S. Supreme Court case New York, Philadelphia & Norfolk Railroad Company v. Peninsula Produce Exchange of Maryland in 1915 revolved around a dispute over freight charges between the railroad company and the produce exchange. The Peninsula Produce Exchange claimed that they were overcharged by the railroad company for transporting strawberries from Virginia to Delaware, arguing that these rates violated federal law as they were unreasonable and discriminatory. The court ruled in favor of the produce exchange, finding that there was indeed discrimination against interstate commerce because similar intrastate shipments on another line owned by the same parent company had lower rates than those charged to Peninsula Produce Exchange for comparable distances under substantially similar conditions.

In the dissenting opinion for the case between New York, Philadelphia & Norfolk Railroad Company and Peninsula Produce Exchange of Maryland, it was argued that the court majority had incorrectly interpreted the Carmack Amendment to apply to intrastate shipments. The dissenting justices believed that this interpretation expanded federal jurisdiction beyond its intended scope. They contended that Congress did not intend for this amendment to regulate commerce within state borders but rather interstate commerce only. Therefore, they disagreed with imposing liability on a carrier under an through bill of lading when damage occurred during an intrastate leg of transportation covered by such bill. In their view, if damages happened during an intrastate shipment segment as part of a larger interstate journey, then local law should govern any claims or disputes arising from those damages instead of federal law under Carmack Amendment.