The U.S. Supreme Court case Chicago, Burlington & Quincy Railway Company v. Miller in 1912 revolved around the issue of whether a railway company could be held liable for damages caused by fire from its locomotives under Nebraska law. The plaintiff, Miller, owned land adjacent to the railroad's tracks and claimed that sparks from passing trains had started fires which damaged his property. He argued that under state law, railroads were responsible for such damage regardless of negligence on their part. However, the defendant railway company contended this state statute was unconstitutional as it violated due process rights guaranteed by the Fourteenth Amendment since it imposed liability without fault. The Supreme Court ruled in favor of Miller stating that while generally laws imposing strict liability might violate due process rights if they are arbitrary or unreasonable; however, given railways' inherent riskiness and potential harm to surrounding properties from fires ignited by locomotive engines - even when operated with utmost care - such legislation is not unreasonable or arbitrary but rather a valid exercise of police power aimed at protecting public safety.

The dissenting opinion in the case of Chicago, Burlington & Quincy Railway Company v. Miller argued that the court majority had erred in its interpretation and application of law. The dissenters believed that there was no legal basis for holding a railway company liable for damages caused by sparks from one of its locomotives when it was not proven to be negligent or at fault. They contended that such an outcome would set a dangerous precedent where companies could be held responsible for accidents beyond their control, potentially leading to unjust outcomes and stifling economic activity due to fear of unwarranted litigation. Furthermore, they disagreed with the majority's view on what constituted "reasonable use" of property, arguing instead that any use which does not infringe upon others' rights should be considered reasonable under law.