In the case of Chesapeake & Ohio Railway Company v. Carnahan, 1915, the U.S Supreme Court ruled in favor of the railway company. The dispute arose when a train owned by Chesapeake & Ohio Railway Company collided with a horse-drawn carriage at an intersection in Indiana, resulting in injuries to those within the carriage and death to one passenger. The victims sued for damages claiming negligence on part of the railway company as they did not provide any warning signals or safety measures at that crossing point despite it being frequently used by public traffic. However, under Indiana law during this time period, railroads were only required to maintain warnings or safeguards at crossings if ordered by local authorities which was not done so here. The court held that while railroads have general obligations towards public safety, specific requirements like installation of warnings are subject to state laws and regulations. Since there was no such order from local authorities requiring these precautions at this particular crossing where accident occurred; hence railroad could not be held liable for negligence due its absence.

The dissenting opinion in the case of Chesapeake & Ohio Railway Company v. Carnahan argued that the majority's decision was inconsistent with previous rulings and principles established by the court. The dissent contended that a railway company should not be held liable for damages caused by sparks from its locomotives if it had taken all reasonable precautions to prevent such incidents, as per common law rules. They believed this principle should apply even when state laws stipulated otherwise, arguing that these laws were unconstitutional because they violated due process rights under the Fourteenth Amendment. In their view, holding companies strictly liable regardless of fault or negligence was unjust and exceeded states' regulatory powers over interstate commerce.