In the 1901 case of Chicago, Rock Island and Pacific Railway Co. v. Eaton, the U.S Supreme Court ruled in favor of the railway company after it was sued by a passenger who had been injured while traveling on one of its trains. The plaintiff, Mr. Eaton, alleged that his injuries were due to negligence on part of the railway company's employees who failed to provide safe transportation as per their duty under common carrier law. However, upon review, it was found that Mr.Eaton himself had contributed significantly to his own injury by disregarding safety instructions provided by train personnel and thus assuming an unnecessary risk for which he alone should bear responsibility.The court held that when a passenger fails to exercise ordinary care for their own safety despite clear warnings from carriers' staff or obvious dangers present in certain actions they undertake during travel (such as standing near open doors), then they cannot hold carriers liable for any resulting harm.This ruling established important precedent regarding contributory negligence in personal injury cases involving common carriers.

In the dissenting opinion for Chicago, Rock Island and Pacific Railway Co. v. Eaton, Justice Harlan disagreed with the majority's interpretation of the law regarding railway companies' liability for damages caused by fires started by their locomotives. He argued that under Iowa state law at that time, a railway company could be held liable if it was proven beyond reasonable doubt that its negligence had directly resulted in a fire causing damage to property. In this case, he believed there was sufficient evidence to prove such negligence on part of the railroad company - namely failure to equip its engines with effective spark arresters as required by statute - which led to Eaton’s loss. Therefore, according to him, the plaintiff should have been allowed recovery from defendant without needing proof of specific acts of carelessness or misconduct at exact time when sparks were emitted starting fire damaging his property.