In the 1914 case of Sligh v. Kirkwood, Sheriff of Orange County, Florida, the U.S. Supreme Court addressed a dispute over an ordinance in Orange County that prohibited transporting "unfit" citrus fruit outside county lines. The plaintiff, Mr. Sligh was arrested for violating this law and he challenged its constitutionality on grounds that it interfered with interstate commerce - a power reserved to Congress under the Commerce Clause of the Constitution. The court ruled against Mr. Sligh stating that while states cannot regulate interstate commerce directly, they can enforce laws protecting health and safety until Congress decides to legislate on such matters itself; thus upholding state's police powers in absence of conflicting federal legislation. This decision affirmed states' rights to enact regulations safeguarding public welfare unless explicitly superseded by federal law or if they place an undue burden on interstate commerce.

In the dissenting opinion for Sligh v. Kirkwood, it was argued that the Florida statute under scrutiny did not violate the Commerce Clause of the U.S. Constitution as claimed by plaintiff. The law in question prohibited transportation and sale of immature citrus fruits within or outside state lines to protect consumers from purchasing unripe produce and to preserve Florida's reputation for quality citrus products. The dissenting justices contended that this regulation fell within a state’s police power to enact laws protecting public health, safety, morals, and welfare - including consumer protection measures like this one - even if they incidentally affected interstate commerce. They believed that such incidental effects on interstate commerce were permissible unless they directly conflicted with federal legislation regulating same subject matter or were discriminatory against out-of-state entities; neither condition existed here according to them.