The United States Supreme Court case of United States v. Atchison, Topeka & Santa Fe Railway Company in 1918 revolved around the interpretation and application of the Hepburn Act (1906), which prohibited railroads from transporting goods they owned across state lines. The U.S. government accused Atchison, Topeka & Santa Fe Railway Company of violating this law by shipping coal it had mined through its subsidiary company to customers outside New Mexico. However, the railway company argued that since it was not directly involved in mining operations but only transported coal as a common carrier for its subsidiary, it did not violate any laws. The Supreme Court ruled in favor of the railway company stating that while technically owning the coal due to its ownership stake in the mining subsidiary, such indirect ownership does not constitute a violation under Hepburn Act's prohibition against railroads transporting their own goods interstate because there is no direct competition with other shippers or carriers.

The dissenting opinion in the case of United States v. Atchison, Topeka & Santa Fe Railway Company argued that the majority decision was incorrect because it failed to properly interpret and apply the Hepburn Act. The dissenters believed that this act did not give the Interstate Commerce Commission (ICC) authority to set rates for private car lines owned by railroads, as these were separate businesses from public transportation services regulated under interstate commerce laws. They contended that allowing ICC regulation over such private entities would be an unjust expansion of federal power into areas traditionally governed by state law or left to free market forces. Furthermore, they disagreed with the majority's interpretation of what constituted "unjust discrimination" under railroad rate regulations, arguing it should only refer to unfair practices between shippers rather than including potential disparities in profits among different types of business operations within a single company like a railway corporation.