The Porter v. Warner Holding Co. case in 1945 revolved around the Price Administrator's authority under the Emergency Price Control Act of 1942 to seek injunctive relief and restitution for overcharges on rent during World War II. The defendant, Warner Holding Company, had been charging tenants more than what was allowed by law due to a housing shortage caused by wartime conditions. The Supreme Court ruled in favor of Porter (the Price Administrator), stating that courts could order both injunctions and restitution as remedies under this act even though it did not explicitly provide for such measures. This decision emphasized the broad powers granted to administrative agencies during times of national emergency.

In the dissenting opinion for Porter v. Warner Holding Co., Justice Frankfurter argued that the majority's decision to uphold a restitution order under the Emergency Price Control Act of 1942 was an overreach of judicial power. He contended that while Congress had indeed granted courts broad powers in enforcing compliance with price controls, it did not intend for them to have unlimited discretion in ordering remedies such as restitution. According to him, this interpretation would essentially transform courts into administrative agencies and blur the separation of powers doctrine fundamental to American constitutional law. Furthermore, he expressed concern about potential abuses stemming from such expansive judicial authority and suggested that any remedy should be proportionate and directly related to actual damages caused by non-compliance with price regulations.