In the case of Canada Packers, Ltd. v. Atchison, Topeka & Santa Fe Railway Co., et al., 1966, the U.S Supreme Court ruled in favor of Atchison, Topeka & Santa Fe Railway Co. The dispute arose when Canada Packers shipped a cargo of meat from Toronto to Los Angeles via several rail carriers including Atchison and claimed that their goods were damaged during transit due to negligence by one or more of these carriers. However, they could not identify which carrier was responsible for the damage. Under common law rules known as "Carmack Amendment," a shipper can hold any participating carrier liable for damages unless it can prove it wasn't at fault; but under an exception called “interline” shipping (where multiple companies handle a shipment), liability is limited only to those segments where damage occurred if proven so by evidence presented by defendants . The court held that this interline rule applied here and since Canada Packers couldn’t specify where along the route its cargo was damaged , it failed in its claim against all involved railway companies.

In the dissenting opinion for Canada Packers, Ltd. v. Atchison, Topeka & Santa Fe Railway Co., Justice Harlan argued that the majority's decision was a departure from established principles of contract law and an unwarranted intrusion into private contractual relationships by the judiciary. He contended that under traditional rules of contract interpretation, when parties to a contract have not specified their intentions regarding certain aspects of performance or risk allocation in their agreement, courts should apply default rules based on societal norms and expectations rather than imposing their own views about what is fair or reasonable. In this case, he believed that because the shipping contracts at issue did not specify who would bear the risk of loss during unloading operations - which were performed by independent contractors hired by consignee - it should be presumed that such risks remained with shipper as part of its general obligation to deliver goods safely to consignee unless explicitly agreed otherwise between parties.