The United States Supreme Court case, United States of America v. Union Stock Yard & Transit Company of Chicago (1912), revolved around the interpretation and application of the Hepburn Act, which was enacted in 1906 to regulate railroad rates and practices. The Interstate Commerce Commission (ICC) had ordered the Union Stock Yard & Transit Company to cease charging for services that were not directly related to transportation under this act. However, the company argued that their charges were justified as they provided additional facilities such as pens and feeding areas for livestock beyond just transportation service. The Supreme Court ruled in favor of ICC stating that these extra services fell within 'transportation' under Hepburn Act's broad definition and thus should be regulated by ICC. This decision affirmed ICC’s authority over ancillary services associated with interstate commerce.

In the dissenting opinion for this case, Justice Holmes disagreed with the majority's view that Union Stock Yard & Transit Company of Chicago was a public utility subject to regulation by the Interstate Commerce Commission. He argued that just because a company performs an essential function does not automatically make it a public service corporation. The nature of its business and how it operates should be considered as well. In his view, Union Stock Yard was more akin to private businesses like hotels or warehouses which provide services but are not regulated as utilities. Furthermore, he contended that if every business integral to commerce were deemed a public utility, then virtually all businesses could fall under federal control - an outcome he believed Congress did not intend when drafting legislation regulating interstate commerce.