In Southern Pacific Co. v. Arizona, concerning whether Arizona could, for safety considerations, require trains traveling through the state be a shorter length than trains traveling through other states. The Supreme Court held the Arizona law was:

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The Supreme Court held that the Arizona law was invalid because it impeded interstate commerce. The Court found that the law was an attempt by Arizona to regulate the operations of a railroad company beyond the state's borders, which was a power that belonged exclusively to Congress. Additionally, the Court found that the law would interfere with the efficiency of interstate commerce by requiring trains to be broken up and reassembled multiple times during their journey through different states.