In the 1890 case of Pullman's Palace Car Company v. Central Transportation Company, the U.S Supreme Court ruled in favor of Pullman's Palace Car Co., stating that a contract between two parties which restrains one party from engaging in any business activity is void due to its violation against public policy. The dispute arose when both companies entered into an agreement where Central Transportation Co. would cease manufacturing sleeping cars and lease all their existing ones to Pullman for a period of 99 years. In return, they were promised annual payment regardless of whether or not these cars were used by Pullman’s company. However, later on, Central Transport decided to breach this contract and started making sleeping cars again which led to legal action being taken by Pullman’s company who sought enforcement of the original agreement.

In the dissenting opinion for Pullman's Palace Car Company v. Central Transportation Company, Justice Bradley argued that the majority had overstepped its bounds by interfering with a private contract between two corporations. He contended that there was no evidence of fraud or illegality in the agreement and therefore it should be upheld as valid under law. Furthermore, he expressed concern about the potential implications of this decision on future business contracts and transactions, suggesting it could create an environment of uncertainty and instability in commercial affairs. In his view, if parties cannot rely on their legally executed agreements being enforced by courts due to arbitrary judicial interference based on subjective notions of public policy or fairness, then confidence in contractual relations would be undermined.