The U.S Supreme Court case Public Utilities Commission of Rhode Island et al. v. Attleboro Steam & Electric Company, 1926, also known as the "Attleboro" case, revolved around a dispute over interstate commerce and state regulation of utility rates. The Public Utilities Commission of Rhode Island had set rates for electricity that was being sold by Narragansett Electric Lighting Co., based in Rhode Island, to Attleboro Steam & Electric Co., located in Massachusetts. However, Attleboro argued that this constituted an interference with interstate commerce and thus fell under federal jurisdiction rather than state authority according to the Commerce Clause of the Constitution. In its decision, the Supreme Court sided with Attleboro Steam & Electric Company stating that while states have power to regulate utilities within their borders when it affects only intrastate business operations; they cannot interfere or regulate prices on energy sales across state lines because such transactions are considered interstate commerce which is subject exclusively to federal control under the Commerce Clause. This ruling led directly to Congress passing legislation creating Federal Power Commission (now Federal Energy Regulatory Commission) in order to fill regulatory gap left by court's decision regarding wholesale electric energy sales between states.

The dissenting opinion in the case of Public Utilities Commission of Rhode Island et al. v. Attleboro Steam & Electric Company argued that the majority's decision was an overreach and misinterpretation of the Commerce Clause, which could potentially lead to federal intrusion into state affairs. The dissenters believed that states should have authority to regulate rates for utilities within their borders, even if those utilities also serve customers in other states. They contended that this type of regulation did not constitute a direct burden on interstate commerce but rather fell under legitimate state police power aimed at protecting public welfare and preventing exploitation by utility companies. Furthermore, they warned against creating a regulatory vacuum where neither federal nor state authorities could exercise control over such matters due to jurisdictional disputes.