In the United States v. Lane et al., 1922, the Supreme Court dealt with a case involving an alleged violation of the National Prohibition Act. The defendants were accused of possessing and transporting intoxicating liquors for beverage purposes in Oklahoma City, which was prohibited under this act. The defense argued that there was no probable cause to justify their arrest or seizure of evidence from their vehicle without a warrant. However, the court ruled against them stating that officers had enough reason to believe they were violating prohibition laws due to suspicious behavior observed prior to stopping them such as changing vehicles and driving at high speed through town late at night. Therefore, it held that these circumstances provided sufficient grounds for immediate action by law enforcement officials without needing a search warrant first.

In the dissenting opinion for United States v. Lane et al., Justice Holmes argued that the majority's interpretation of the Sherman Act was too broad and could potentially criminalize normal business practices. He contended that not all price-fixing agreements should be considered illegal per se, as some may actually promote competition rather than restrict it. Furthermore, he believed that only those agreements which unreasonably restrain trade should be deemed unlawful under the Act. In his view, a more nuanced approach to interpreting this legislation would better serve its intended purpose of promoting fair competition in commerce among states or with foreign nations.