In Willis Shaw Frozen Express, Inc. v. United States et al., the U.S Supreme Court dealt with a dispute over the Interstate Commerce Commission's (ICC) authority to regulate trucking rates for frozen food transportation. The petitioner, Willis Shaw Frozen Express, was a carrier specializing in transporting frozen poultry and had established its rates based on an agreement with shippers. However, ICC declared these rates as unreasonable and ordered increased charges without considering evidence of competitive conditions presented by the carrier which would justify lower prices than those set by similar carriers not facing competition from other modes of transport like railroads or waterways. The Supreme Court ruled in favor of ICC stating that it did have such regulatory power under the Interstate Commerce Act even if there were competitive conditions present that could potentially allow for lower pricing structures. It held that while competition is one factor to be considered when determining reasonable rates, it does not necessarily override all others nor compel a finding of reasonableness where actual costs are not covered.

In the dissenting opinion for Willis Shaw Frozen Express, Inc. v. United States et al., Justice Harlan argued that the Interstate Commerce Commission (ICC) had overstepped its authority by imposing a blanket prohibition on leasing arrangements between independent truckers and regulated carriers without considering individual circumstances. He contended that such an absolute ban was not necessary to prevent abuses or protect public interest, as there were other less restrictive means available to achieve these goals. Furthermore, he expressed concern about the impact of this decision on small businesses and independent operators who relied on these leasing agreements for their livelihoods. According to him, it was not within ICC's power to make such broad policy decisions affecting economic relationships in the industry; rather it should be left up to Congress.