The U.S. Supreme Court case Georgia, Florida & Alabama Railway Company v. Blish Milling Company in 1915 revolved around the issue of liability for goods damaged during transit. The Blish Milling Company had shipped a consignment of corn which was damaged due to negligence by the railway company's employees while being transported from Indiana to Georgia via multiple carriers under a through bill of lading (a contract covering transportation over various lines). The court held that under the Carmack Amendment - an amendment regulating interstate commerce - when damage occurs en route and it is impossible to determine where along the journey it happened, then each carrier involved can be held liable until they prove their innocence. Therefore, even though there were several carriers involved in this shipment process, since none could provide evidence showing that they did not cause or contribute to the damage done on corns; all were found responsible for compensating Blish Milling Co., including Georgia, Florida & Alabama Railway Co.

In the dissenting opinion for Georgia, Florida & Alabama Railway Company v. Blish Milling Company, it was argued that the majority's decision to hold a carrier liable for damages caused by delay in transit due to an act of God or public enemy contradicts established principles and precedents. The dissent emphasized that carriers should not be held responsible when they have exercised all possible care and diligence but are prevented from fulfilling their obligations due to unforeseen events beyond their control. It was also pointed out that this ruling could lead to unjust consequences as it would force carriers into assuming risks they cannot manage or predict, potentially leading them into financial ruin. Furthermore, the dissent questioned whether such liability is even within Congress' power under commerce clause jurisprudence.