In the case of St. Louis Hay and Grain Co. v. United States, 1903, the U.S Supreme Court ruled in favor of the United States government regarding a dispute over import duties on hay. The St. Louis Hay and Grain Company had imported hay from Canada into Minnesota but refused to pay an imposed duty arguing that under Article XXII of a treaty between Great Britain (acting for Canada) and America, it was exempted from such charges as it was "natural products" or "produce". However, the court held that this exemption only applied to goods transported across land borders by teams or vehicles not involving maritime transportation which wasn't applicable here since their shipment came through waterways via steamboat transport hence subjecting them to import duties according to customs laws at that time.

In the dissenting opinion for St. Louis Hay and Grain Co. v. United States, it was argued that the Interstate Commerce Commission (ICC) did not have the authority to determine what constituted a reasonable rate for rail transportation of goods between states. The dissenting justices believed that this power should be left to Congress or state legislatures, as they are directly accountable to voters and thus better positioned to make such determinations in line with public interest. They also expressed concern about potential overreach by regulatory bodies like ICC, warning against an unchecked expansion of their powers without clear legislative guidance or oversight from elected officials.