The Southern Railway Company v. United States case in 1911 revolved around the interpretation of the Safety Appliance Act passed by Congress in 1893, which required all trains to be equipped with automatic couplers and continuous brakes. The Southern Railway Company was charged for violating this act as some of its cars were not fitted with these safety appliances. The company argued that it should not be held liable because those particular cars were leased from another company and they had no control over their equipment. However, the Supreme Court ruled against them stating that under the law, any railway company using such vehicles on its lines is responsible regardless of who owns or controls them. This decision underscored a broad interpretation of federal regulatory power aimed at enhancing public safety.

In the dissenting opinion for Southern Railway Company v. United States, Justice Harlan argued that the majority's interpretation of the Hepburn Act was incorrect. He believed that Congress did not intend to give such broad powers to the Interstate Commerce Commission (ICC) over railroad rates without judicial review. According to him, this would be a violation of due process rights under the Fifth Amendment as it deprives railroads of their property without fair compensation or an opportunity for a hearing in court. Furthermore, he contended that if Congress had intended such sweeping changes in regulatory power and constitutional protections, they would have explicitly stated so in clear language within legislation itself rather than leaving it up to inference by courts or administrative bodies like ICC.