In the case of Chicago & Alton Railroad Company et al. v. McWhirt, 1916, the U.S Supreme Court was asked to determine whether a state court could exercise jurisdiction over an out-of-state corporation in relation to a personal injury claim. The plaintiff, McWhirt, had been injured while working for the railroad company in Missouri and sought compensation through Illinois courts as he resided there. The defendant argued that since they were not incorporated or primarily operating within Illinois, its courts lacked jurisdiction over them. The Supreme Court ruled against this argument stating that corporations conducting substantial business within a state can be subject to its laws even if they are not physically present or incorporated there. This decision established important precedent regarding states' rights and their ability to regulate interstate commerce under certain conditions.

In the dissenting opinion for Chicago & Alton Railroad Company et al. v. McWhirt, it was argued that the court majority had erred in its interpretation of the law and precedent cases. The dissenting justices believed that there was no legal basis to hold a railroad company liable for damages caused by sparks from one of its locomotives if it could be proven that all necessary precautions were taken to prevent such an incident from occurring. They contended that this ruling would place an unfair burden on railroad companies, forcing them into a position where they are held responsible even when they have done everything within their power to prevent harm. This view emphasized strict adherence to principles of negligence and fault-based liability rather than imposing absolute liability regardless of preventative measures taken.