In the case of Walsh v. Columbus, Hocking Valley and Athens Railroad Company in 1899, the U.S Supreme Court was tasked with determining whether a state could regulate railroad rates without violating due process rights under the Fourteenth Amendment. The plaintiff, Walsh, had been charged more than what he believed to be reasonable for transporting his goods by rail within Ohio. He argued that this violated his constitutional right to due process as it allowed an unfair advantage to other businesses who were charged less for similar services. However, the court ruled against him stating that states have inherent power over corporations operating within their boundaries and can therefore set maximum freight charges if they deem it necessary for public welfare or preventing discrimination among customers.

In the dissenting opinion for Walsh v. Columbus, Hocking Valley and Athens Railroad Company, it was argued that the majority's decision to uphold a state law requiring railroads to provide separate accommodations for smokers and non-smokers infringed upon interstate commerce regulations. The dissent contended that this ruling would allow individual states to impose their own varying rules on railroad companies operating across multiple jurisdictions, creating an untenable situation of conflicting laws. They believed this could potentially disrupt or impede interstate trade and travel by imposing undue burdens on railway operators who must comply with different sets of rules in each state they operate within. Therefore, they asserted that such matters should be regulated at a federal level rather than left up to individual states' discretion.