The U.S. Supreme Court case Pittsburgh, Cincinnati and St. Louis Railway Company v. Keokuk and Hamilton Bridge Company in 1894 revolved around a dispute between two railway companies over the use of a bridge across the Mississippi River at Keokuk, Iowa. The plaintiff, Pittsburgh, Cincinnati and St. Louis Railway Company (PC&StL), argued that it had an exclusive right to use the bridge under its lease agreement with the defendant company who owned it - Keokuk & Hamilton Bridge Co., which was denying PC&StL's trains access to cross unless they paid tolls for each crossing separately from their lease agreement. The court ruled against PC&StL stating that while their lease did grant them rights to operate on certain tracks leading up to and away from the bridge as well as some terminal facilities; it did not specifically include any rights or privileges related directly to using this particular bridge itself without paying additional fees if required by its owner.

The dissenting opinion in the case of Pittsburgh, Cincinnati and St. Louis Railway Company v. Keokuk and Hamilton Bridge Company argued that the majority's decision was inconsistent with previous rulings on similar issues. The dissenters believed that a bridge built by a private company over navigable waters should not be considered an obstruction to interstate commerce unless it significantly interferes with navigation. They contended that the mere existence of such a bridge does not constitute an interference, especially when there is no evidence showing any actual or potential harm to navigation caused by its presence. Furthermore, they disagreed with the majority's view that Congress has exclusive authority over all structures spanning navigable waters, arguing instead for shared jurisdiction between federal and state governments based on historical precedent and practical considerations.