In the 1931 case of Stevens v. The White City, the Supreme Court was asked to determine whether a contract for exclusive docking rights at a Chicago harbor violated antitrust laws. The plaintiff, Stevens, had entered into an agreement with The White City (a company that owned and operated amusement devices) where he would provide transportation services to their patrons in exchange for exclusive docking privileges at their harbor on Lake Michigan. However, after another boat operator began providing similar services without such an agreement and docked his boats at the same location, Stevens sued alleging breach of contract and violation of antitrust laws. The Supreme Court ruled against Stevens stating that there was no violation of antitrust law as it did not restrain trade or commerce among states nor did it monopolize any part thereof which is prohibited by Sherman Act. It further stated that even if there were violations under state law regarding unfair competition or interference with contractual relations these issues should be addressed in state courts rather than federal ones.

The dissenting opinion in the case of Stevens v. The White City argued that the majority's decision to uphold a lower court ruling, which found in favor of The White City amusement park after an injury on one of its rides resulted in a death, was incorrect. They contended that there were significant questions about whether or not the ride operator had been negligent and if this negligence directly led to the fatal accident. Furthermore, they disagreed with how evidence was interpreted and presented during trial proceedings. In their view, these issues should have warranted a new trial rather than simply upholding the previous verdict without further examination into potential errors made during litigation process.