In the case of Bankers Mutual Casualty Company v. Minneapolis, St. Paul and Sault Sainte Marie Railway Company in 1903, the Supreme Court was tasked with determining liability for a fire that started on railway property but spread to nearby buildings owned by Bankers Mutual Casualty Company. The company argued that the railway was negligent in allowing conditions conducive to a fire outbreak on its premises and should therefore be held responsible for their losses. However, after careful consideration of both parties' arguments and existing laws regarding negligence and liability, the court ruled in favor of the railroad company. It stated that while it is true that fires can start from sparks emitted by locomotives, this does not automatically mean negligence on part of railroads as such occurrences are common incidents associated with operation of trains which cannot be entirely avoided despite exercising due care.

The dissenting opinion in the case of Bankers Mutual Casualty Company v. Minneapolis, St. Paul and Sault Sainte Marie Railway Company argued that the majority's decision was inconsistent with previous rulings regarding liability for damages caused by fires started by locomotives. The dissenting justices believed that a railway company should be held liable for any fire damage caused by its operations, regardless of whether negligence could be proven or not. They contended that this strict liability principle had been established in earlier cases and should have been applied here as well. Furthermore, they disagreed with the majority's interpretation of Minnesota law on this issue, arguing instead that state law did indeed impose such strict liability on railway companies.