The control of the relations between the public and the various public service commissions or boards is now quite general throughout the country. The movement started during the last third of the nineteenth century with the formation of the various railroad boards and railroad commissions, to which were usually given certain powers of control over relations between the public and the railroads. But the courts, under the influence of the extreme individualistic notions of the time, were so hostile to any exercise of any real power by such administrative boards that these boards were almost completely paralyzed, and, as one might say, their morale was destroyed, so that as a rule they refrained from any action which would be likely to be taken into the courts for review.
James W. Simonton,
Judicial Control of the Missouri Public Service Commission,
30 Bulletin Law Series.
Available at: https://scholarship.law.missouri.edu/ls/vol30/iss1/4