In the United States v. Pierce Auto Freight Lines, Inc., 1945, the Supreme Court dealt with a dispute over labor relations and collective bargaining agreements. The Interstate Commerce Commission (ICC) had approved an increase in freight rates for certain trucking companies to cover increased labor costs resulting from a new collective bargaining agreement. However, some of these companies were not parties to that agreement and argued they should not have to pay higher rates as their labor costs hadn't risen accordingly. The Supreme Court ruled in favor of these trucking companies stating that ICC's decision was arbitrary because it failed to consider whether each individual company’s situation justified an increase in freight rates due to increased wage expenses under the new union contract.

In the dissenting opinion for United States v. Pierce Auto Freight Lines, Inc., Justice Frank Murphy argued that the Interstate Commerce Commission (ICC) had overstepped its bounds by imposing a rate increase on trucking companies without sufficient evidence to justify such an action. He contended that the ICC's decision was based largely on assumptions and generalizations rather than concrete data or specific findings related to individual carriers' financial situations. Furthermore, he criticized the majority's deference to administrative agencies like the ICC, warning of potential abuses of power if these entities were allowed unchecked discretion in their decision-making processes. In his view, courts should play a more active role in reviewing agency decisions to ensure they are grounded in fact and law.