The U.S. Supreme Court case Cleveland, Cincinnati, Chicago & St. Louis Railway Company v. Dettlebach in 1915 revolved around the issue of whether a railway company was liable for damages caused by sparks from one of its locomotives setting fire to property near the tracks. The plaintiff, Dettlebach, owned a warehouse that was destroyed by such a fire and sued for compensation under Ohio state law which held railroads strictly liable for fires caused by their operations regardless of negligence or fault on part of the railroad company. However, the defendant argued that this law conflicted with federal laws regulating interstate commerce as it imposed an unfair burden on out-of-state companies operating within Ohio's borders. In its decision, the Supreme Court ruled in favor of Dettlebach stating that while Congress had power over interstate commerce regulations; states were not prohibited from enacting safety measures or imposing liability rules unless they directly conflicted with federal legislation or impeded free flow of trade across state lines - neither condition being met here according to court’s judgement.

In the dissenting opinion for Cleveland, Cincinnati, Chicago & St. Louis Railway Company v. Dettlebach (1915), Justice Holmes disagreed with the majority's ruling that a railway company could be held liable for injuries sustained by an individual who was not employed by them but was working on their premises under contract from another company. He argued that this interpretation of liability extended beyond what he believed to be reasonable boundaries and would place undue burden on businesses to ensure safety in situations where they may have limited control or oversight. Furthermore, he contended that such broad interpretations of liability could potentially discourage companies from contracting work out to other businesses due to fear of legal repercussions if accidents occur.