In the 1985 case of Square D Co. et al. v. Niagara Frontier Tariff Bureau, Inc., et al., the United States Supreme Court ruled in favor of Niagara Frontier Tariff Bureau and other defendants who were accused by Square D Company and others of violating antitrust laws through collective ratemaking activities for motor carrier transportation rates under the Interstate Commerce Act (ICA). The plaintiffs argued that these actions violated federal antitrust law as they constituted price-fixing agreements among competing carriers. However, the court held that such collective ratemaking was within a regulatory framework established by Congress under ICA which provided immunity from antitrust laws to certain collaborative rate-setting practices among competitors if approved by an appropriate regulatory agency - in this case, the Interstate Commerce Commission (ICC). Therefore, since ICC had sanctioned these practices as being in line with public interest and not detrimental to competition overall, they were immune from prosecution under federal anti-trust legislation.

In the dissenting opinion for SQUARE D CO. et al. v. NIAGARA FRONTIER TARIFF BUREAU, INC., et al., Justice White disagreed with the majority's decision that antitrust immunity should be granted to collective ratemaking agreements approved by the Interstate Commerce Commission (ICC). He argued that this ruling contradicted previous court decisions and Congress' intent when it enacted the Reed-Bulwinkle Act, which allowed certain types of rate bureaus to operate under ICC supervision without violating antitrust laws. According to Justice White, only those activities explicitly authorized by a specific order from the ICC should receive such immunity; otherwise, there would be an unwarranted expansion of exemptions from competition law.