In the 1942 case Roche, U.S. District Judge, et al. v. Evaporated Milk Association et al., the United States Supreme Court addressed a dispute over an injunction issued by a district court against enforcement of certain orders from the Secretary of Agriculture under the Agricultural Marketing Agreement Act of 1937. The Evaporated Milk Association and several dairy companies had challenged these orders as unconstitutional and beyond statutory authority; they also alleged that their due process rights were violated because they weren't given notice or opportunity to be heard before issuance of these orders affecting milk prices in Illinois markets. The Supreme Court held that while courts could review such administrative actions for constitutionality or compliance with enabling legislation, it was inappropriate to issue an injunction without first exhausting available administrative remedies - which included seeking modification or termination through public hearings provided for in the statute itself. Furthermore, regarding due process claims, it ruled that since this was not adjudication but rule-making affecting broad industry standards (not individual rights), no prior hearing was required – though affected parties should have post-issuance opportunities to challenge rules' reasonableness or lawfulness.

In the dissenting opinion for Roche, U.S. District Judge, et al. v. Evaporated Milk Association et al., Justice Frank Murphy argued that the majority's decision to uphold a district court injunction against enforcement of price regulations set by the Secretary of Agriculture was incorrect and undermined administrative law principles. He contended that courts should not interfere with administrative decisions unless they are clearly unlawful or unconstitutional; in this case, he saw no such clear violation. Furthermore, he criticized the majority for failing to give due deference to an agency's interpretation of its own enabling statute - a principle known as "Chevron deference." In his view, if there is ambiguity in how a law should be applied or interpreted, it is up to agencies (not courts) to resolve that ambiguity based on their expertise and judgment.