The U.S. Supreme Court case Chicago, Milwaukee & St. Paul Railway Company v. Polt in 1913 revolved around a dispute over the liability of a railway company for injuries sustained by an employee while on duty. The plaintiff, Mr. Polt, was injured when he fell from a moving train car due to allegedly defective equipment provided by his employer - the defendant railway company. The court had to determine whether or not the Federal Employers' Liability Act (FELA) applied and if it did, whether it superseded state laws that might otherwise limit or bar recovery for such injuries. In its decision, the Supreme Court held that FELA did apply as it covered all cases where interstate carriers were liable for damages resulting from injury or death of their employees during employment; thus federal law took precedence over any conflicting state laws under the Supremacy Clause of Constitution. However, despite this ruling favoring federal jurisdiction and applicability of FELA in principle,the court also found there wasn't enough evidence presented at trial proving negligence on part of railway company i.e., no proof was offered showing defects in equipment caused accident leading to injury.Therefore,the judgement went against Mr.Polt.

In the dissenting opinion for the case of Chicago, Milwaukee & St. Paul Railway Company v. Polt, Justice Holmes disagreed with the majority's decision to hold a railway company liable for damages caused by sparks from one of its locomotives igniting hay on a farmer's property. He argued that there was no negligence involved as it is common knowledge that sparks are an inevitable result of operating steam engines and thus should not be considered negligent behavior in itself. Furthermore, he contended that if every spark produced by a train could potentially lead to liability claims against railway companies, this would place an unreasonable burden on them and hinder their operations significantly. Therefore, he believed that unless there was evidence showing specific negligence or misconduct on part of the railway company leading to such damage (which wasn't present in this case), they shouldn't be held responsible.