The U.S. Supreme Court case Railroad Commission of Texas et al. v. Rowan & Nichols Oil Co., 1939, revolved around the issue of oil production regulation by the state government in Texas and its potential violation of property rights under the Fourteenth Amendment's due process clause. The Railroad Commission of Texas had imposed a proration order limiting oil extraction to prevent waste and conserve resources, which was challenged by Rowan & Nichols Oil Co as an infringement on their constitutional rights to use their property freely without unreasonable governmental interference. However, the court ruled in favor of the commission stating that such regulations were within a state's police power for protecting public interests like conserving natural resources or preventing economic instability caused by overproduction.

In the dissenting opinion for Railroad Commission of Texas et al. v. Rowan & Nichols Oil Co., Justice Black argued that the majority's decision to strike down a state regulation limiting oil production was an overreach of judicial power, infringing upon states' rights to regulate their own natural resources. He contended that it is not within the Court’s purview to determine whether or not such regulations are wise or unwise, necessary or unnecessary; these decisions should be left up to legislative bodies and administrative agencies who have been given this authority by law. Furthermore, he expressed concern about potential negative consequences on conservation efforts due to this ruling and warned against courts substituting their judgment for those with specialized knowledge in complex fields like oil production and conservation.