In the case of Southern Railway Company v. Railroad Commission of Indiana, 1914, the U.S. Supreme Court ruled in favor of Southern Railway Company. The court held that a state could not force an interstate railroad to stop at all stations within its borders if it interfered with interstate commerce or was unreasonable and discriminatory against other states' interests. This decision came after the Railroad Commission of Indiana ordered Southern Railway to make regular stops at every station along its route within Indiana's borders for passenger trains running between Louisville and St Louis via Evansville - an order which was challenged by the railway company as being burdensome and interfering with their ability to conduct business efficiently across state lines.

In the dissenting opinion for Southern Railway Company v. Railroad Commission of Indiana, Justice Holmes argued that the court should not have intervened in this case as it was a matter of state regulation. He believed that the State had every right to regulate rates within its borders and if those regulations resulted in losses for interstate commerce, then it would be an issue to take up with Congress rather than the courts. The justice emphasized that states should retain their autonomy unless there is clear evidence of constitutional violation or federal preemption. Furthermore, he pointed out that no such evidence existed in this case; hence, he disagreed with majority's decision which seemed to undermine state authority over local matters without sufficient justification.