The U.S. Supreme Court case Atchison, Topeka & Santa Fe Railway Company v. Robinson in 1913 revolved around the issue of whether a railway company could be held liable for damages caused by sparks from its locomotives igniting flammable materials on nearby property. The plaintiff, Robinson, had sued the railway company after his hay and grass were set ablaze by sparks from one of their trains passing through his land in Kansas. The court ruled that even though there was no negligence on part of the railroad company as it used best available technology to prevent such incidents and followed all regulations, they would still be held responsible under strict liability because railroads are inherently dangerous operations which can cause damage without any fault or negligence involved.

The dissenting opinion in the case of Atchison, Topeka & Santa Fe Railway Company v. Robinson argued that the majority's decision to uphold a state law requiring railroads to provide separate accommodations for black and white passengers was incorrect. The dissenters believed that this law violated the Fourteenth Amendment's Equal Protection Clause, which guarantees all citizens equal protection under the law. They contended that segregation inherently implied inequality and thus could not be considered "equal" treatment under any circumstances. Furthermore, they disagreed with the majority's assertion that it was within a state’s power to regulate railroad companies as long as such regulations did not interfere with interstate commerce or federal laws; they maintained instead that states should not have authority over matters concerning civil rights and racial discrimination because these issues were of national importance.