In the 1897 case Pullman's Palace Car Company v. Central Transportation Company, the U.S Supreme Court ruled that a contract between two companies was void because it violated antitrust laws. The Pullman's Palace Car Company had entered into an agreement with the Central Transportation Company in which they agreed not to compete with each other for 999 years and instead share profits equally. However, when Pullman tried to buy out Central’s interest as per their agreement, Central refused leading to this lawsuit. The court held that such agreements were against public policy as they eliminated competition and created monopolies, thereby violating antitrust laws designed to protect consumers from predatory business practices by ensuring there are enough rival businesses in open-market economies so prices remain low due to competition.

In the dissenting opinion for Pullman's Palace Car Company v. Central Transportation Company, Justice Harlan argued that the majority had overstepped its bounds by interfering with a contract between two private corporations. He contended that there was no evidence of public harm or violation of state law in this case and therefore, it should not have been within the purview of federal courts to dissolve an agreement freely entered into by both parties. Furthermore, he disagreed with the majority's view that Pullman had monopolistic tendencies; instead, he saw them as providing a valuable service to railroads and passengers alike through their sleeping car operations. In his view, if any party felt aggrieved by such contracts they could seek redress in court but it was not for judges to preemptively strike down such agreements on mere suspicion of potential future harm or wrongdoing.