The U.S. Supreme Court case Railroad and Warehouse Commission of Minnesota et al. v. Duluth Street Railway Company in 1926 revolved around the issue of rate regulation for public utilities, specifically street railways, by state commissions. The Duluth Street Railway Company challenged an order from the Railroad and Warehouse Commission of Minnesota that reduced their rates without allowing them to present evidence on whether this would allow a reasonable return on investment or not. The company argued that this violated their due process rights under the Fourteenth Amendment as it deprived them of property (i.e., potential earnings) without a fair hearing or just compensation. In its decision, the Supreme Court sided with the railway company stating that while states have broad powers to regulate public utilities' rates, they must also respect companies' constitutional rights including due process protections under law when doing so; hence any such regulatory action should be based on adequate factual investigation and opportunity for hearing.

In the dissenting opinion for the case of Railroad and Warehouse Commission of Minnesota et al. v. Duluth Street Railway Company, it was argued that the state regulatory body had overstepped its authority by attempting to regulate a private corporation's rates without providing sufficient evidence or justification for such action. The dissenting justices believed that this constituted an infringement on property rights as protected under due process clause of Fourteenth Amendment, arguing that any regulation must be reasonable and not arbitrary or discriminatory in nature. They contended that there was no clear proof presented showing how proposed rate changes would result in fair returns for company while also being just and reasonable to public interest; thus, they deemed commission’s order as unjustified interference with corporate management decisions which should have been left within purview of business discretion unless proven otherwise.