In the case of Chicago, Burlington & Quincy Railroad Company v. Harrington (1915), the U.S Supreme Court ruled in favor of the railroad company. The dispute arose when a train operated by the company collided with a wagon driven by Harrington, resulting in his death. His widow sued for damages under Nebraska state law which allowed recovery if negligence could be proven on part of the defendant and no contributory negligence was present from plaintiff's side. However, this conflicted with federal laws that permitted partial recovery even if there was some degree of contributory negligence from plaintiff's side as long as it wasn't greater than defendant’s fault (comparative negligence). The court held that since railroads engaged in interstate commerce were governed primarily by federal law rather than individual state laws, comparative negligence should apply instead of Nebraska’s strict rule barring any recovery if there is any level of contributory fault on part of plaintiff.

In the dissenting opinion for the case of Chicago, Burlington & Quincy Railroad Company v. Harrington, it was argued that there was no legal basis to hold the railroad company liable for damages caused by a fire started by sparks from one of its locomotives. The dissenting justices contended that while negligence could be inferred if proper spark arresters were not in use or were defective, there was no evidence presented to suggest this had been the case. They further pointed out that even with all due precautions taken, it is impossible to guarantee absolute safety against fires when operating trains. Therefore, they believed holding railroads responsible without clear proof of negligence would place an undue burden on them and potentially hinder their operations significantly.