In the 1956 case of Pan-Atlantic Steamship Corp. v. Atlantic Coast Line Railroad Co., the U.S Supreme Court ruled on a dispute involving transportation charges for goods shipped from foreign ports to inland destinations in the United States. The issue was whether or not Pan-Atlantic, as an ocean carrier, could collect freight charges based on through rates filed by rail carriers with whom they had no direct contractual relationship. The court held that under Section 7 of the Intercoastal Shipping Act 1933 and Sections 1 and 6(7) of Interstate Commerce Act (ICA), an ocean common carrier cannot lawfully participate in joint through routes or charge joint through rates unless such routes are established and such rates are published pursuant to tariffs duly filed with Federal Maritime Board (FMB). As there were no tariffs filed by Pan-Atlantic with FMB, it was not entitled to collect any portion of rail-water rate but only its own independent water rate.

The dissenting opinion in the case of Pan-Atlantic Steamship Corp. v. Atlantic Coast Line Railroad Co., et al., argued that the majority's decision to hold a shipper liable for damages caused by an accident during transportation was inconsistent with previous rulings and federal law governing interstate commerce. The dissent, led by Justice Frankfurter, contended that under the Interstate Commerce Act (ICA), liability should be placed on carriers rather than shippers unless there is explicit agreement otherwise between both parties involved in shipping goods. They believed this interpretation of ICA would ensure fairness and predictability within commercial transactions involving carriage of goods across state lines. Furthermore, they disagreed with the majority's view that a clause exempting carriers from liability due to negligence could be implied from silence or ambiguous language in contracts or bills of lading.