In the case of Queenside Hills Realty Co., Inc. v. Saxl, Commissioner of Housing and Buildings of the City of New York (1945), the U.S Supreme Court ruled in favor of Saxl, upholding a local law that required landlords to provide heat for their tenants during certain hours from October 1st through May 31st each year. The plaintiff, Queenside Hills Realty Co., argued that this law was unconstitutional as it violated their rights under the Fourteenth Amendment's Due Process Clause by imposing an arbitrary and unreasonable regulation on property owners. However, the court disagreed with this argument stating that such regulations were within a city’s police power to protect public health and welfare. Therefore, they found no violation against constitutional rights or due process.

The dissenting opinion in the Queenside Hills Realty Co., Inc. v. Saxl case argued that the majority's decision to uphold a New York City ordinance requiring landlords to provide heat for their tenants was an overreach of government power and violated property rights. The dissent contended that it is not within the purview of government to dictate how private property should be used or managed, including setting specific standards for heating rental properties. They believed this type of regulation could lead to excessive governmental interference in private affairs, potentially infringing upon individual liberties and free enterprise principles. Furthermore, they expressed concern about potential economic consequences such as increased housing costs due to additional regulatory burdens on landlords.