Atchison, T. & S. F. Ry. v. United States
In Atchison, T. & S. F. Ry. v. United States, 284 U.S. 248, 52 S.Ct. 146, 76 L.Ed. 273 (1932), the Interstate Commerce Commission ("ICC") had entered an order prescribing maximum rates for the shipment of grain in the western part of the United States.
The evidentiary record had been closed in September, 1928, but the Commission's final order was only issued in April, 1931, after two applications for rehearing had been denied.
The Supreme Court held unanimously that the existing record in the case pertained to a different economic era, and that it was incumbent upon the Commission to conduct a new hearing to determine the effects of the Great Depression, "the outstanding contemporary fact, dominating thought and action throughout the country." 284 U.S. at 260, 52 S.Ct. at 149.