In the case of Chicago & Eastern Illinois Railroad Company v. Collins Produce Company, 1918, the Supreme Court ruled in favor of Collins Produce Company. The dispute arose when a shipment of strawberries was delayed by the railroad company and arrived spoiled at its destination. The produce company sued for damages due to negligence on part of the railroad company and won in lower courts. However, upon appeal to the Supreme Court, it was argued that under federal law (the Carmack Amendment), railroads were not liable for losses caused by delays unless they had agreed to deliver goods within a specific time frame - which wasn't applicable here as no such agreement existed between both parties. Despite this argument from Chicago & Eastern Illinois Railroad Co., the court upheld previous rulings stating that while there may not have been an explicit delivery deadline set out in their contract with Collins Produce Co., there still existed an implicit obligation on behalf of carriers like them to transport perishable goods without unreasonable delay.

The dissenting opinion in the case of Chicago & Eastern Illinois Railroad Company v. Collins Produce Company argued that the railroad company should not be held liable for damages to a shipment of strawberries due to delay caused by flooding. The dissent emphasized that the contract between both parties clearly stated that the carrier would not be responsible for losses resulting from "unavoidable delays." It was further noted that floods are generally considered an act of God, which is typically recognized as a valid defense against liability claims in such cases. Therefore, it was contended that since there were no indications or allegations suggesting negligence on part of the railroad company and given their inability to control or predict natural disasters like floods, they should not bear responsibility for any loss incurred due to these unforeseen circumstances.