In the case of Eastern Railway Company of New Mexico v. Littlefield, 1914, the U.S Supreme Court ruled in favor of Littlefield. The dispute arose when a train owned by Eastern Railway Company hit and killed several cattle belonging to Mr. Littlefield who had wandered onto an unfenced portion of the railway's track. The company argued that it was not liable for damages as per New Mexico’s territorial law which stated that livestock owners were responsible for preventing their animals from straying onto railways if they were fenced or enclosed properly on both sides with wire fences at least four feet high. However, this particular section was not fenced due to geographical difficulties making it impossible to do so effectively. The court held that since fencing wasn't possible in this area due to natural obstacles, the railway company could not claim immunity under territorial laws requiring such fencing as a prerequisite for liability protection against damage caused by wandering livestock; thus ruling in favor of Mr.Littlefield.

In the dissenting opinion for Eastern Railway Company of New Mexico v. Littlefield, Justice Holmes disagreed with the majority's ruling that a railroad company could be held liable for damages caused by sparks from its locomotives. He argued that such liability was not consistent with common law principles and would place an undue burden on railway companies. According to him, it is unreasonable to expect railroads to completely eliminate all risks associated with their operations as they provide essential public services and should therefore be granted some degree of immunity from lawsuits related to those inherent risks. Furthermore, he contended that if a person chooses to live near a railway line, they must accept certain risks associated with proximity to such operations.