In the 1915 case O'Keefe, Receiver of New Orleans, Texas & Mexico Railroad Company v. United States and the Interstate Commerce Commission (ICC), the Supreme Court ruled on an issue related to railroad rates. The ICC had ordered a reduction in rates charged by several railroads for interstate transport of goods. One of these railroads was under receivership at that time and its receiver challenged this order arguing it would cause financial harm to creditors who were owed money by the bankrupt company. The court held that while a receiver has certain rights as representative of creditors, they do not have standing to challenge rate orders issued by ICC because such challenges must be brought directly by companies themselves or their shareholders rather than third parties like receivers or trustees acting on behalf of others.

In the dissenting opinion for O'Keefe v. United States and The Interstate Commerce Commission, Justice Holmes argued that the court should not have intervened in this case as it was a matter of administrative discretion rather than judicial review. He believed that the Interstate Commerce Commission (ICC) had acted within its statutory authority when it ordered New Orleans, Texas & Mexico Railroad Company to cease discriminatory practices against certain shippers. According to him, whether or not these orders were reasonable was a question for the ICC to decide based on their expertise and experience in regulating interstate commerce. Therefore, he disagreed with majority's decision which held that courts could overturn such orders if they found them unreasonable or unjustifiable.