The United States Supreme Court case of United States v. Chicago, Burlington and Quincy Railroad Company in 1914 revolved around the interpretation of the Act to Regulate Commerce. The U.S government sued the railroad company for allegedly giving preferential treatment to certain shippers by providing them with private sidetracks while charging others for similar services. The court had to determine whether such actions constituted unjust discrimination under the act. In its decision, it held that a railroad company could provide free sidetrack facilities without violating anti-discrimination provisions if there was no additional cost involved in doing so and if it did not result in prejudice against other shippers who were charged for equivalent services elsewhere on their line. However, where charges are made they must be reasonable and justifiable based on actual costs incurred by the railway company.

In the dissenting opinion for United States v. Chicago, Burlington and Quincy Railroad Company, Justice Holmes argued that the Interstate Commerce Commission (ICC) had overstepped its authority by ordering railroads to provide free transportation for federal employees inspecting their operations. He contended that this requirement was not a reasonable regulation of commerce but rather an imposition on private businesses to support government functions without compensation. This, he believed, violated the Fifth Amendment's prohibition against taking private property for public use without just compensation. Furthermore, he asserted that if such inspections were necessary for public safety or other reasons within ICC's purview then Congress should appropriate funds to pay for them instead of forcing these costs onto railroad companies.