In the United States v. Morgan case of 1940, the U.S. Supreme Court ruled on a dispute involving the Secretary of Agriculture's authority to fix maximum rates charged by stockyard companies under the Packers and Stockyards Act of 1921. The Secretary had set rates after an investigation but without a formal hearing, which J.P. Morgan & Co., as majority owners in one affected company, challenged as unconstitutional due to lack of due process rights. The court held that while administrative orders are subject to judicial review for constitutionality or statutory authority, courts cannot reevaluate factual determinations made during agency proceedings unless there is no evidence supporting them at all - known as "substantial evidence" standard. Furthermore, Justice Frankfurter clarified that when reviewing such cases in future, courts should not substitute their judgment for that of legislative bodies or administrative agencies acting within their own sphere; rather they should only determine whether those entities have acted within constitutional and statutory limits. This decision upheld broad powers for federal regulatory agencies and established important precedents regarding judicial review standards applied to administrative decisions.

In the dissenting opinion for United States v. Morgan, Justice McReynolds disagreed with the majority's decision to uphold a federal order setting maximum rates that stockyards could charge meatpackers. He argued that this was an overreach of government power and violated principles of due process. According to him, it was not within the purview of Congress or any administrative body to fix prices in private industries without providing affected parties an opportunity for judicial review. Furthermore, he contended that such actions would lead to arbitrary price-setting by bureaucrats who lacked understanding about specific business operations and market conditions. In his view, this case represented a dangerous expansion of governmental control over private enterprise which threatened individual liberty and economic freedom.