In the 1943 case Southern Railway Co. v. United States, the Supreme Court ruled that a railroad company could not claim immunity from federal antitrust laws on the grounds of being part of an interstate commerce network. The case arose when several railroads were accused by the U.S government of violating antitrust laws through price-fixing and monopolistic practices in their handling of coal transportation rates in Alabama, Georgia, North Carolina and South Carolina. The railroads argued they were immune to these charges because they operated under regulations set by Interstate Commerce Commission (ICC). However, this argument was rejected by Justice Hugo Black who stated that although ICC had regulatory power over railways' activities related to interstate commerce; it did not grant them immunity from other federal laws including those against anti-competitive behavior.

In the dissenting opinion for Southern Railway Co. v. United States, Justice Frank Murphy argued that the majority's decision to uphold a federal regulation requiring railroads to install automatic train control devices was an overreach of governmental power. He contended that there was insufficient evidence proving these devices would significantly improve safety and thus justify their high installation costs borne by railroad companies. Furthermore, he believed this ruling could set a dangerous precedent where government agencies might impose burdensome regulations on private industries without sufficient justification or consideration of potential economic impacts. In his view, such decisions should be made by Congress rather than administrative bodies or courts as they involve complex policy considerations beyond mere legal interpretations.