In the case of Oklahoma Natural Gas Company v. Russell et al., 1922, the U.S Supreme Court dealt with a dispute between a private gas company and the state's Corporation Commission over rate regulation. The Oklahoma Natural Gas Company argued that an order by the commission to reduce its rates was unconstitutional as it violated their rights under Fourteenth Amendment - specifically, it deprived them of property without due process of law and denied them equal protection under law. However, after examining evidence presented on operating costs, profits and other relevant factors in determining reasonable utility rates, the court upheld that such regulatory power is within states' authority for public interest purposes. Therefore, they ruled against Oklahoma Natural Gas Company stating that there was no constitutional violation because setting fair utility rates falls within legitimate exercise of police powers by states.

In the dissenting opinion for Oklahoma Natural Gas Company v. Russell et al., Justice Holmes disagreed with the majority's decision to strike down an Oklahoma law that regulated gas prices. He argued that states should have broad powers to regulate businesses within their borders, especially when it comes to setting fair and reasonable rates for public utilities like natural gas companies. In his view, if a state believes such regulation is necessary to protect its citizens from excessive charges or monopolistic practices, then it has every right to do so under its police power. Furthermore, he contended that courts should defer more often than not to legislative judgments about what constitutes a fair rate of return on investment for utility companies unless there is clear evidence of confiscatory intent or effect.