In the case of Toledo, St. Louis & Western Railroad Company v. Allen in 1927, the U.S Supreme Court ruled on a dispute involving railroad freight charges. The plaintiff, Allen, had shipped goods via the defendant's railway and was charged based on a tariff filed with the Interstate Commerce Commission (ICC). However, he argued that this rate was unreasonable and sought to recover alleged overcharges from Toledo Railway Company. The court held that it did not have jurisdiction to determine whether or not rates approved by ICC were reasonable as long as they were within its statutory authority; such determination is exclusively for ICC itself under federal law. Therefore, if shippers believe an established rate is unjust or unreasonable they must first seek redress before ICC rather than courts directly.

In the dissenting opinion for Toledo, St. Louis & Western Railroad Company v. Allen, Justice Stone argued that the majority's decision to uphold a state law requiring railroads to provide free transportation for railroad commissioners and their staff was incorrect. He contended that this requirement constituted an unjust taking of property without compensation, violating the Fourteenth Amendment's due process clause. Furthermore, he disagreed with the majority’s view that such services were part of a quid pro quo exchange between railroads and states in return for certain privileges granted by states; instead, he saw it as an arbitrary imposition on companies operating interstate commerce which could potentially lead to discriminatory practices among different states if each imposed its own set of requirements or demands on these companies.