In the 1927 case of Delaware, Lackawanna and Western Railroad Company v. Rellstar, the U.S Supreme Court was tasked with determining whether a railroad company could be held liable for damages caused by sparks from one of its locomotives. The plaintiff, Rellstar, had suffered property damage when sparks from a passing train ignited a fire on his land. He argued that the railroad company should have taken preventative measures to avoid such an incident. However, the court ruled in favor of the defendant - Delaware, Lackawanna and Western Railroad Company - stating that it was not responsible for unforeseeable accidents resulting from ordinary operations conducted without negligence or misconduct. This ruling set an important precedent regarding liability in cases involving accidental fires caused by railway operations.

The dissenting opinion in the case of Delaware, Lackawanna and Western Railroad Company v. Rellstar argued that the majority's decision to hold the railroad company liable for damages was incorrect. The dissenting justices believed that there was no negligence on part of the railroad company as they had followed all safety protocols and regulations. They contended that accidents can occur even when all precautions are taken, and it is unjust to penalize a party for unforeseeable circumstances beyond their control. Furthermore, they expressed concern over setting a precedent where companies could be held responsible for any accident occurring within their premises regardless of fault or negligence on their part.