In the 1940 case of Armour & Company v. Alton Railroad Co., the U.S Supreme Court was asked to determine whether a railroad company could be held liable for damages incurred by a shipper due to delays in transit, even if those delays were not caused by negligence on part of the railroad. The plaintiff, Armour & Company, had shipped meat products via Alton Railroad and claimed that their goods spoiled because they were not transported promptly as promised. The defendant argued that it should not be responsible for losses resulting from unforeseen circumstances beyond its control such as weather conditions or mechanical failures. However, the court ruled in favor of Armour & Company stating that under federal law (the Carmack Amendment), rail carriers are liable for any damage or loss to property they transport unless they can prove that they weren’t negligent and that the damage was caused solely by an act of God, public enemy, authority of law or act/omission by shipper himself.

In the dissenting opinion for Armour & Company v. Alton Railroad Co., Justice Black argued that the majority's decision to uphold a state law requiring railroads to provide refrigeration services for meat shipments was an overreach of federal power. He contended that this ruling effectively allowed states to regulate interstate commerce, which is constitutionally reserved for Congress. Furthermore, he expressed concern about the potential economic impact on railroad companies and other industries if they were forced to comply with varying regulations across different states. This could lead to inefficiencies and increased costs due to lack of uniformity in regulation standards, ultimately harming both businesses and consumers alike.