In the case of Rock Island, Arkansas & Louisiana Railroad Company v. United States in 1920, the Supreme Court ruled on a dispute over freight rates set by the Interstate Commerce Commission (ICC). The railroad company argued that these rates were too low and violated their rights under due process clause of Fifth Amendment. However, the court upheld ICC's authority to regulate interstate commerce including setting reasonable rail rates. It stated that while corporations have property rights protected by due process clause, this does not prevent government from regulating economic activities for public interest. Therefore, as long as ICC’s rate-setting was not arbitrary or unreasonable and provided fair return to companies it could be deemed constitutional even if it affected profitability of businesses involved.

The dissenting opinion in the case of Rock Island, Arkansas & Louisiana Railroad Company v. United States disagreed with the majority's interpretation of the Hepburn Act (1906). The dissent argued that Congress did not intend to give absolute power to the Interstate Commerce Commission (ICC) over railroad rates without any judicial review. They believed that such an interpretation would be unconstitutional as it violates due process rights by depriving railroads of their property without a fair hearing. Furthermore, they contended that if Congress had intended for such sweeping powers to be given to ICC, it should have been explicitly stated in clear and unambiguous terms within the legislation itself.