In the 1896 case of Savannah, Florida and Western Railway Company v. Florida Fruit Exchange, the U.S. Supreme Court dealt with a dispute over freight charges for transporting oranges from Florida to New York. The railway company had charged rates based on an agreement made with other railroads but did not have a similar contract with the fruit exchange. The fruit exchange sued for recovery of alleged overcharges, arguing that they were entitled to lower rates under federal law which required railways to charge "reasonable" prices and prohibited them from giving preferential treatment by charging different customers different rates for essentially identical services. The court ruled in favor of the railway company stating that while it was true that railways could not discriminate between shippers or give undue preference, there was no evidence presented showing any such discrimination or preference in this case. Furthermore, it held that what constituted a reasonable rate was primarily up to railroad companies themselves unless their decision is challenged before Interstate Commerce Commission (ICC) - something which hadn't been done here.

In the dissenting opinion for Savannah, Florida and Western Railway Company v. Florida Fruit Exchange, Justice Harlan argued that the majority's decision was inconsistent with previous rulings of the Court regarding interstate commerce. He contended that by allowing states to regulate rates for transportation within their borders even when such transportations were part of a longer journey across state lines, it would disrupt and burden interstate commerce. This could potentially lead to each state setting its own rules without regard to how they might affect other states or overall national trade policy. Furthermore, he believed this ruling gave too much power to individual states at the expense of federal authority over matters involving multiple states - an area where he felt federal law should prevail according to Constitution’s Commerce Clause.