The Great Northern Railway Company v. Cahill et al., 1919, was a case that revolved around the issue of whether or not a railway company could be held liable for damages caused by fire due to negligence in maintaining its equipment. The plaintiffs, Redman & Cahill, alleged that sparks from one of the defendant's locomotives ignited dry grass and spread to their property causing damage. The Supreme Court ruled in favor of the plaintiffs stating that even though there were no specific regulations requiring spark arresters on locomotives at the time of incident, it was still within common knowledge and practice for companies to use such devices as preventative measures against fires. Therefore, failure to do so constituted negligence on part of the railway company making them responsible for resulting damages.

In the dissenting opinion for Great Northern Railway Company v. Cahill et al., it was argued that the majority's decision to hold a railroad company liable for damages caused by sparks from its locomotive, despite state law absolving them of such liability, contradicted previous rulings and principles of federalism. The dissent contended that this case should be governed by local laws as per the Erie Doctrine - which holds that federal courts sitting in diversity jurisdiction must apply state substantive law. They believed there was no valid reason to disregard Minnesota’s fire statute, which explicitly exempted railroads from liability for fires started unintentionally. By ignoring this provision and imposing liability on the railway company anyway, they felt the court had overstepped its boundaries and infringed upon states' rights to regulate their own affairs.