[1] PUHCA was one of a number of trust-busting and securities regulation initiatives that were enacted in response to the Wall Street Crash of 1929 and ensuing Great Depression, including the collapse of Samuel Insull's public utility holding companies.

North American then registered in 1937 as a holding company with the SEC, reserving its right to challenge the validity of the remaining portions of PUHCA.

The opinion by Justice Murphy first concluded that North American was engaged in interstate commerce and through its substantial stock ownership dominated its subsidiaries.

Lastly, the Court dismissed the takings argument, noting that Congress had weighed the benefit to shareholders of efficient, common management of diversified companies against the actual and potential harm to the public, investors, and consumers from the use of pooled investments, and determined that the economic advantages of a holding company atop an unintegrated, sprawling electric system were not commensurate with the resulting economic disadvantages.

The Court determined that it could not conclude that North American shareholders were disadvantaged by the operation of the divestiture provision of PUHCA.