Are you talking about Shreveport?
I wasn’t specifically thinking about the Shreveport Rate Case. There are plenty enough instances of the feds lording it over the railroads for me to bypass specific instances. And in Houston E & WT Railroad Co. I think they might have relied on the necessary and proper clause (as in controlling intrastate rates was necessary to prevent the bogey of “predatory pricing “ on the interstate level). Perhaps without Gibbons they never would have dared use necessary and proper in that manner. We’ll never know.