In the 1916 case of Van Dyke et al. v. Geary et al., members of the Corporation Commission of Arizona, plaintiffs challenged an order by the Arizona Corporation Commission that reduced freight rates on intrastate shipments within Arizona by railroads operating in both interstate and intrastate commerce. The Supreme Court held that while states have power to regulate purely internal affairs, they cannot interfere with or burden interstate commerce which is under federal control according to Commerce Clause (Article I, Section 8) of U.S Constitution. The court ruled in favor of defendants stating that it was not shown convincingly how this reduction would affect interstate traffic adversely or discriminate against it unfairly; hence there was no violation committed by state authorities.

In the dissenting opinion for Van Dyke et al. v. Geary et al., it was argued that the majority's decision to uphold an Arizona law regulating railroad rates violated principles of due process and equal protection under the Fourteenth Amendment. The dissent contended that railroads were being unfairly singled out for regulation, while other businesses were allowed to set their own prices without interference from state authorities. Furthermore, they expressed concern about potential harm to interstate commerce if individual states could arbitrarily dictate terms of trade within their borders. They also disagreed with the majority's assertion that courts should defer to legislative judgment on economic matters, arguing instead for a more active judicial role in protecting property rights against potentially arbitrary or discriminatory government action.