The United States Supreme Court case, United States of America v. Lexington Mill & Elevator Company in 1913 revolved around the interpretation and application of the Pure Food and Drug Act of 1906. The government accused Lexington Mill & Elevator Company of misbranding its product by labeling it as "bleached flour" when it was actually treated with nitrogen peroxide, a bleaching agent that could potentially be harmful to consumers' health. The company argued that their use of the term "bleached" was not misleading because it accurately described the physical appearance change in their flour due to treatment with nitrogen peroxide. However, the Supreme Court ruled against them stating that even if a label is technically true, if it fails to disclose facts material in light of representations made or suggested by words or designs on such label regarding consequences which may result from customary usage thereof under conditions prescribed in such label or under ordinary conditions then it can still be considered misleading according to Section 8 (a) and (b) respectively; thus violating provisions set forth by Pure Food and Drug Act.

In the dissenting opinion for United States of America v. Lexington Mill & Elevator Company, Justice Holmes disagreed with the majority's interpretation of the Pure Food and Drug Act. He argued that it was not intended to regulate commerce in a way that would prevent businesses from selling products simply because they were misbranded or adulterated according to standards set by government officials. Instead, he believed that Congress had only meant to prohibit false labeling or branding which could deceive consumers about what they were buying. The justice also expressed concern over giving too much power to administrative bodies like the Department of Agriculture, warning against allowing them unchecked authority in determining what constitutes an adulterated product without clear guidelines from legislation itself.