In the Atlantic Coast Line Railroad Company v. Mazursky case of 1909, the U.S Supreme Court ruled in favor of Atlantic Coast Line Railroad Company. The dispute arose when a shipment of bananas was damaged during transport due to an alleged delay by the railroad company. Mazursky, who owned the bananas, sued for damages and won at both trial court and South Carolina's highest state court levels. However, on appeal to the Supreme Court, it was determined that there had been no unreasonable delay in transportation as per Interstate Commerce Act standards because weather conditions were not taken into account by lower courts while determining what constituted "reasonable" time for delivery under normal circumstances. Therefore, since these adverse weather conditions (a hurricane) were beyond human control and could not have been foreseen or prevented by any amount of care or foresight on part of carrier i.e., they constituted an 'Act Of God', this exempted them from liability for delays caused thereby.

In the dissenting opinion for Atlantic Coast Line Railroad Company v. Mazursky, Justice Holmes disagreed with the majority's decision to overturn a South Carolina state court ruling that allowed an injured employee to sue his employer. He argued that federal courts should not interfere in state matters unless absolutely necessary and believed this case did not meet such criteria. The justice contended that it was within South Carolina’s rights as a sovereign state to enact laws protecting its citizens from injury at work, even if those laws differed from other states or were seen as burdensome by corporations operating across multiple jurisdictions. Furthermore, he asserted that there was no violation of due process because companies like Atlantic Coast Line Railroad had willingly chosen to do business in South Carolina and therefore agreed implicitly to abide by its laws.