In the case of Great Northern Railway Company v. Capital Trust Company, Administrator of Ward (1916), the U.S Supreme Court was tasked with determining whether a state court could exercise jurisdiction over an out-of-state corporation in relation to a personal injury claim. The plaintiff, Capital Trust Co., acting as administrator for Ward's estate, sued Great Northern Railway Co. for damages following Ward's death in a train accident that occurred outside Montana where he lived and worked but within territory covered by the railway company’s operations. The key issue revolved around due process rights under Fourteenth Amendment and whether it would be violated if Montana courts exercised jurisdiction over this matter involving an out-of-state defendant. The Supreme Court ruled that since Great Northern had substantial business activities in Montana including owning property and employing workers there, it constituted "presence" within the state thus making them subject to its laws and judicial system. Therefore, despite being incorporated elsewhere (Minnesota), they were not immune from legal action taken against them in other states where they conducted significant business operations like Montana. This ruling affirmed lower courts' decisions allowing such suits against foreign corporations operating extensively within their jurisdictions.

In the dissenting opinion for Great Northern Railway Company v. Capital Trust Company, Administrator of Ward (1916), it was argued that the majority's decision to hold the railway company liable for damages resulting from a fire caused by sparks from one of its locomotives was incorrect. The dissenting justices believed that there wasn't sufficient evidence to prove negligence on part of the railway company and hence, they should not be held responsible for any damage caused by such fires unless negligence can be proven beyond reasonable doubt. They also pointed out that holding companies accountable in this way could have far-reaching implications on industries where risks are inherent and unavoidable, potentially leading to an unfair burden being placed upon them.