In the 1938 case of Utah Fuel Co. et al. v. National Bituminous Coal Commission et al., the U.S Supreme Court ruled on a dispute involving coal companies and a federal commission established to regulate them under the Bituminous Coal Act of 1937, which was enacted to stabilize prices and labor conditions in the industry. The plaintiffs, including Utah Fuel Company, challenged provisions of this act that allowed for price-fixing by producers' groups subject to approval by the National Bituminous Coal Commission (NBCC). They argued these provisions violated their rights under both antitrust laws and constitutional protections against deprivation of property without due process or equal protection under law. The court upheld most parts of the act but struck down those allowing producer price-fixing as an unconstitutional delegation of legislative power to private parties (the producers' groups). It also found that certain penalties imposed by NBCC were not authorized by Congress when it passed this legislation.

In the dissenting opinion for Utah Fuel Co. et al. v. National Bituminous Coal Comm'n et al., Justice McReynolds expressed concern over the constitutionality of the Bituminous Coal Conservation Act of 1935, which established a commission to regulate coal prices and labor conditions in order to stabilize and improve the industry during The Great Depression. He argued that Congress had exceeded its powers under the Commerce Clause by attempting to directly control production within states, rather than interstate commerce itself - an action he believed was reserved for state governments alone under federalism principles enshrined in Tenth Amendment. Moreover, he criticized majority's reliance on emergency circumstances (economic crisis) as justification for such broad interpretation of congressional power; warning against potential erosion of constitutional limits on government authority if allowed unchecked expansion based on temporary exigencies or perceived needs.