In the 1911 case of Union Pacific Railroad Company v. Mason City and Fort Dodge Railroad Company, the Supreme Court was asked to determine whether a railroad company could be compelled to allow another company's trains to use its tracks. The dispute arose when Union Pacific refused access to its Omaha bridge and terminal facilities by Mason City & Fort Dodge Railroad. The Interstate Commerce Commission (ICC) ordered Union Pacific to provide reasonable and non-discriminatory access, but this decision was challenged in court. The Supreme Court upheld the ICC's order, ruling that under the Interstate Commerce Act, railroads are considered public highways established for trade and transportation purposes. Therefore, they must serve all who need their services without discrimination or undue preference. This landmark decision reinforced federal regulatory authority over interstate commerce activities.

In the dissenting opinion for Union Pacific Railroad Company v. Mason City and Fort Dodge Railroad Company, it was argued that the majority's decision to allow Union Pacific to charge higher rates for shorter hauls was inconsistent with previous rulings of the Court. The dissent pointed out that this case involved a clear violation of long- and short-haul clause in Interstate Commerce Act which prohibits railroads from charging more per mile for a short distance than for a longer one over the same line in the same direction unless authorized by Interstate Commerce Commission after full investigation. They contended that there had been no such authorization here, thus making Union Pacific's actions illegal under federal law. Furthermore, they disagreed with majority’s interpretation of “under substantially similar circumstances and conditions” phrase used in act as too narrow because it would make enforcement impossible due to difficulty proving similarity beyond reasonable doubt.