In the Waters-Pierce Oil Company v. State of Texas case in 1908, the Supreme Court ruled on a dispute involving antitrust laws and interstate commerce. The state of Texas had accused Waters-Pierce Oil Company, an affiliate of Standard Oil, of violating state antitrust laws by engaging in monopolistic practices and conspiring to fix prices. The company was fined $1,623,000 and its permit to do business within the state was revoked. On appeal to the Supreme Court, Waters-Pierce argued that it was being unfairly targeted for conduct that occurred outside Texas' jurisdiction as part of interstate commerce which should be governed by federal law rather than individual states'. However, the court upheld Texas's right to enforce its own antitrust legislation within its borders even if those actions impacted interstate trade indirectly. It affirmed both fine imposed on Waters-Pierce and revocation of their permit.

In the dissenting opinion for Waters-Pierce Oil Company v. State of Texas, Justice Oliver Wendell Holmes Jr. argued that the court had overstepped its boundaries by interpreting state law instead of deferring to the interpretation given by state courts. He believed that it was not within their jurisdiction to decide whether or not a corporation could be penalized under Texas law without being found guilty in a jury trial first, as this was an issue of local and not federal concern. Furthermore, he disagreed with the majority's view on due process rights, arguing that corporations should have no more protection than individuals under these laws and thus should be subject to penalties if they violate them just like any other entity would be.