In the 1910 case of Atlantic Coast Line Railroad Company v. Riverside Mills, the U.S. Supreme Court was tasked with determining whether a railroad company could be held liable for damages to goods that were destroyed in a fire while being transported by rail. The court ruled in favor of Riverside Mills, stating that under common law and federal statutes, carriers are responsible for any damage or loss to property they transport unless it can be proven that they took all necessary precautions and care to prevent such an occurrence from happening. In this particular instance, the railroad company failed to provide sufficient evidence proving their due diligence in preventing the fire; therefore, they were held accountable for the losses incurred by Riverside Mills as a result of their negligence.

The dissenting opinion in the case of Atlantic Coast Line Railroad Company v. Riverside Mills argued that the majority's decision to allow a shipper to recover full damages from an initial carrier for loss or damage caused by another carrier along a continuous route was incorrect. The dissent contended that this ruling contradicted previous decisions and common law principles, which held each individual carrier responsible only for their own segment of transportation. It also pointed out inconsistencies between this judgment and the Carmack Amendment, which intended to hold carriers accountable only for their portion of transport unless they explicitly accepted liability for entire routes through special contracts. The dissent further suggested that allowing shippers to sue any involved party would lead to unjust outcomes as it could force innocent parties into litigation while potentially absolving guilty ones from responsibility.