The Grand Trunk Western Railway Company v. United States case in 1919 revolved around the issue of whether or not a railway company could be held liable for damages caused by fires that were allegedly started by sparks from its locomotives. The U.S. government had sued the Grand Trunk Western Railway Company to recover money it spent fighting forest fires and replanting trees on federal land, arguing that these costs should be borne by the railway company as they resulted from negligence on their part. However, the Supreme Court ruled in favor of the railway company, stating that there was no federal common law under which such a claim could be made and therefore dismissed it. This decision established an important precedent regarding liability for environmental damage caused by industrial activities.

In the dissenting opinion for the Grand Trunk Western Railway Company v. United States case, Justice McReynolds disagreed with the majority's interpretation of the Hepburn Act. He argued that it was not Congress' intention to give such broad power to Interstate Commerce Commission (ICC) in regulating railroad companies' free services and passes. According to him, ICC’s authority should be limited only to prevent unfair practices or preferences which could harm commerce among states; it shouldn't interfere with railroads’ internal affairs unless necessary for public interest protection. Furthermore, he believed that this kind of regulation would lead towards a dangerous expansion of federal control over private businesses without clear legislative mandate or constitutional justification.