In the 1923 case of Atchison, Topeka & Santa Fe Railway Company v. Wells et al., the U.S Supreme Court ruled in favor of the railway company. The dispute arose when a group of landowners sued Atchison, Topeka & Santa Fe Railway for damages caused by fires that started from sparks emitted by its locomotives. However, under Kansas law at that time, railroads were not liable for such damages unless negligence could be proven. The plaintiffs argued this state law was superseded by an act of Congress (the Safety Appliance Act), which they claimed imposed absolute liability on railroads for all fire damage caused by their operations regardless of negligence. The court disagreed with this interpretation and held that while federal laws regulate many aspects of railroad safety equipment to prevent accidents and protect employees, these do not extend to providing compensation for property owners affected by operational side effects like sparks causing fires - unless there is proof of negligence or violation on part of the railways as per state laws.

In the dissenting opinion for Atchison, Topeka & Santa Fe Railway Company v. Wells et al., Justice Holmes disagreed with the majority's decision to uphold a state law that allowed injured employees to sue their employers in states other than where the injury occurred or where the employment contract was made. He argued that this interpretation of jurisdiction violated due process rights and exceeded constitutional limits on state power. Holmes believed it unfair for companies to be subjected to lawsuits in any state they conducted business, as it could lead them into legal systems unfamiliar and potentially unfavorable towards them. He also expressed concern about potential forum shopping by plaintiffs seeking more favorable jurisdictions, which he saw as undermining uniformity and predictability in law enforcement across different states.