The U.S. Supreme Court case Woods, Housing Expediter v. Stone in 1947 revolved around the issue of rent control during a time when housing was scarce following World War II. The Federal government had enacted legislation to control rents and prevent price gouging, but there were questions about whether this power extended to properties that had been voluntarily vacated by tenants rather than being rented out continuously. In this case, the landlord argued that he should be allowed to raise his rents because his property had been vacant for some time before it was re-rented at a higher rate. However, the court ruled against him stating that even if a property is voluntarily vacated, it still falls under federal jurisdiction for rent control purposes as long as it remains within the rental market.

In the dissenting opinion for Woods, Housing Expediter v. Stone, Justice Frankfurter disagreed with the majority's interpretation of the Emergency Price Control Act and its application to housing rental agreements. He argued that Congress did not intend for this law to apply in such a way as to interfere with state laws governing landlord-tenant relationships or contracts between private parties. Furthermore, he believed that if Congress had intended such an expansive reach of federal power into these areas, it would have explicitly stated so in clear language within the statute itself. Therefore, he concluded that applying this federal law to override existing state laws and contractual agreements was beyond what was authorized by Congress and constituted an overreach of federal authority.