In the case of Baltimore & Ohio Southwestern Railway Company v. Voigt, 1899, the U.S Supreme Court ruled in favor of Voigt. The dispute arose when a shipment of beer was damaged during transit by the railway company due to freezing temperatures. The court held that it was within the carrier's responsibility to protect goods from damage caused by cold weather if such conditions could be reasonably anticipated and prevented against with ordinary care and diligence. It further stated that this duty existed even without explicit instructions from the shipper regarding protection against cold weather unless there is an agreement relieving them from liability for such damages or they are exempted under common law rules applicable to carriers.

In the dissenting opinion for Baltimore & Ohio Southwestern Railway Company v. Voigt, Justice Peckham disagreed with the majority's interpretation of the Interstate Commerce Act. He argued that it was not Congress' intention to allow railroads to charge more for shorter distances than longer ones under any circumstances, as this would be inherently unjust and unreasonable. Instead, he believed that such a practice should only be permitted in exceptional cases where it could be proven necessary due to competition or other special circumstances. Furthermore, he contended that even if such exceptions were allowed by law, they should still have been subject to review by courts or regulatory bodies like the Interstate Commerce Commission (ICC). In his view, allowing railroads absolute discretion over their rates without oversight would lead to abuse and exploitation of consumers.