In the 1899 case Doherty v. Northern Pacific Railway Company, the U.S Supreme Court ruled in favor of the railway company. The plaintiff, Doherty, had sued for damages after a fire allegedly started by one of the defendant's locomotives burned his property. However, he was unable to provide sufficient evidence that linked this specific incident directly to his loss. The court held that while it is generally accepted that sparks from a locomotive can start fires under certain conditions and therefore railroads are liable for such damage if negligence can be proven; in this particular case there was no direct or circumstantial evidence proving beyond reasonable doubt that the fire which caused damage to Doherty’s property originated from Northern Pacific Railway Company's engine as claimed by him.

In the dissenting opinion for Doherty v. Northern Pacific Railway Company, it was argued that the court majority erred in its interpretation of liability under federal law. The dissent contended that a railway company should not be held liable for damages caused by wildfires sparked by sparks from its locomotives unless there is proof of negligence on part of the company. It was asserted that holding companies responsible without evidence of carelessness would set an unfair precedent and could potentially cripple industries vital to national growth and development. Furthermore, they believed this ruling contradicted previous decisions where courts had ruled against imposing such strict liabilities on corporations operating in hazardous but necessary fields like rail transportation.