In the 1933 U.S. Supreme Court case Cullen Fuel Co., Inc. v. W.E. Hedger, Inc., the court was tasked with determining whether a contract for coal delivery could be voided due to an "Act of God" clause in the agreement that excused performance during events beyond human control such as storms or strikes. The defendant, W.E Hedger, had contracted with Cullen Fuel Company to deliver coal but failed to do so citing labor disputes and strikes at their mines which they claimed were unforeseen circumstances covered by the Act of God clause in their contract. The Supreme Court ruled against W.E Hedger stating that labor disputes and strikes are not Acts of God because they can be anticipated and planned for unlike natural disasters or other uncontrollable events like war or government action which would qualify under this provision. This ruling clarified what constitutes an Act of God in legal contracts providing guidance on how these clauses should be interpreted going forward thereby setting a precedent for future cases involving similar issues.

In the dissenting opinion for Cullen Fuel Co., Inc. v. W.E. Hedger, Inc., Justice Stone argued that the majority's decision to uphold a lower court ruling in favor of Hedger was incorrect because it failed to consider important aspects of maritime law and contract interpretation principles. He believed that the agreement between both parties did not explicitly state or imply that Cullen would be held responsible for any damages caused by its failure to deliver coal on time due to unforeseen circumstances such as strikes or other disruptions beyond their control (force majeure). Furthermore, he contended that under maritime law, unless expressly stated otherwise in a contract, liability for such events typically falls on the party who is supposed to receive goods (in this case Hedger), rather than those delivering them (Cullen). Therefore, he concluded that Cullen should not have been found liable for breach of contract and damages.