In the case of Standard Oil Company of Indiana v. State of Missouri, 1911, the Supreme Court upheld a lower court's decision that found Standard Oil guilty of creating a monopoly and violating antitrust laws in Missouri. The company was accused by Attorney General Hadley (later succeeded by Major) for using predatory pricing to drive competitors out of business and control the petroleum market in violation with state law. The court ruled that it was within states' rights to regulate commerce within their borders and protect against monopolistic practices. This ruling reinforced previous decisions regarding anti-competitive behavior under Sherman Antitrust Act, emphasizing on maintaining fair competition among businesses operating within individual states.

In the dissenting opinion for Standard Oil Company of Indiana v. State of Missouri, Justice Oliver Wendell Holmes Jr., joined by Justices Harlan and Lurton, argued that the majority's decision to uphold a fine against Standard Oil was based on an incorrect interpretation of Missouri law. They contended that the state statute did not prohibit price discrimination as such but only when it was used with intent to destroy competition or create a monopoly. The dissenters believed there wasn't sufficient evidence proving this intention from Standard Oil’s part in its pricing practices within different markets across states. Furthermore, they disagreed with the majority's view that selling goods below cost could be considered prima facie evidence of harmful intent under all circumstances; instead, they suggested this should depend on specific market conditions and business strategies at play.