In United States v. Erie Railway Company, the United States Supreme Court addressed the issue of whether the federal government had the power to regulate the rates of a private railroad company. The case arose when the United States sued the Erie Railway Company for charging excessive rates for the transportation of goods. The United States argued that the Interstate Commerce Act of 1887 gave the federal government the power to regulate the rates of private railroads. The Erie Railway Company argued that the Act was unconstitutional because it violated the Tenth Amendment, which reserves powers not delegated to the federal government to the states. The Supreme Court held that the Interstate Commerce Act was constitutional and that the federal government had the power to regulate the rates of private railroads. The Court reasoned that the power to regulate interstate commerce was granted to Congress by the Commerce Clause of the Constitution, and that the Act was a valid exercise of that power. The Court also held that the Act did not violate the Tenth Amendment because it did not interfere with the states' power to regulate intrastate commerce. The Court's decision in United States v. Erie Railway Company established the federal government's power to regulate the rates of private railroads and set an important precedent for the regulation of interstate commerce.

Justice Field delivered the dissenting opinion in United States v. Erie Railway Company, arguing that the majority had misconstrued a key provision of the Interstate Commerce Act. He argued that Congress intended to prohibit railroads from charging more for short than long hauls and not just those within one state but between states as well. The majority’s interpretation would allow railroads to charge different rates for similar services depending on whether they were intrastate or interstate, which he believed was contrary to Congressional intent and could lead to discrimination against out-of-state shippers. Justice Field further argued that if Congress wanted only intrastate commerce regulated it would have used language limiting its application accordingly rather than using broad terms like “all charges” and “any person or persons whatsoever” which clearly indicated an intention to regulate both types of commerce equally.