The United States Supreme Court case of the United States v. The Fruit Growers Express Company in 1928 revolved around a dispute over taxation. The Fruit Growers Express Company, which was involved in interstate commerce through its business of leasing refrigerated cars to transport perishable goods, contested an income tax assessment by arguing that it should be exempted under the Commerce Clause and Due Process Clause of the Constitution. However, the government argued that as long as a tax does not directly burden interstate commerce or discriminate against it, such tax is permissible. The Supreme Court ruled in favor of the government stating that there was no constitutional barrier preventing Congress from imposing an income tax on corporations engaged in interstate commerce so long as it did not interfere with their operations nor discriminate against them.

The dissenting opinion in the case of United States v. The Fruit Growers Express Company argued that the Interstate Commerce Commission (ICC) had overstepped its authority by attempting to regulate practices outside of its jurisdiction. It was contended that the ICC's decision to set rates for refrigeration services provided by Fruit Growers Express, a private company, violated principles of free enterprise and competition. The dissent further asserted that such regulation should only apply if it can be proven beyond reasonable doubt that existing market conditions are detrimental or unfair to consumers or other businesses - something which they believed hadn't been sufficiently demonstrated in this case. They also questioned whether Congress had intended for the ICC's powers to extend so far when drafting legislation related to interstate commerce.