In the 1916 case of Wilson v. New, the U.S. Supreme Court ruled on a dispute involving federal wage regulations for railway workers under the Adamson Act. The Missouri, Oklahoma & Gulf Railway Company had been placed into receivership and its operations were being managed by court-appointed receivers when it was sued by United States Attorney Wilson for non-compliance with these wage laws. The company argued that as a receiver-operated entity, it was not subject to such regulation because it functioned more like a public utility than an interstate commerce business. However, the Supreme Court disagreed and held that even though in receivership, railroads are still engaged in interstate commerce and therefore must comply with federal labor standards set forth in legislation like the Adamson Act.

In the dissenting opinion for Wilson v. New, Justice McReynolds disagreed with the majority's decision to uphold a federal law that set minimum wages for railroad workers. He argued that Congress did not have the constitutional authority to regulate wages in this way because it interfered with private contracts and violated principles of states' rights. He believed that such wage regulations should be left up to individual states rather than being imposed by the federal government. Furthermore, he contended that if Congress could set minimum wages for railroads, there would be no limit to its power over other industries or aspects of commerce. This view was rooted in a strict interpretation of the Constitution and an emphasis on limited government intervention in economic affairs.