In the 1938 case of Great Northern Railway Co. et al. v. Leonidas, the U.S Supreme Court ruled in favor of the railway company and against a group of farmers who had sued for damages caused by fires allegedly started by sparks from passing trains on their lands in Montana. The court held that under federal law, specifically the Federal Employers' Liability Act (FELA), which governs railroad worker injury claims, there was no provision allowing landowners to sue railroads for property damage caused by fire sparked from train operations unless it could be proven that such fires were intentionally set or resulted from negligence on part of the railroad companies. The ruling effectively limited FELA's scope only to injuries suffered by employees and not third-party claims like those brought forward by these farmers.

In the dissenting opinion for the case of Great Northern Railway Co. et al. v. Leonidas, it was argued that the majority's decision to hold railroads liable for damages caused by fires started unintentionally and without negligence contradicts previous rulings and established principles of law. The dissent emphasized that liability should only be imposed when there is a breach of duty or neglect, not merely because damage occurred as an unintended consequence of lawful activities conducted with due care. It was further contended that this ruling would place an unfair burden on railroad companies, potentially leading to unjust outcomes in future cases involving similar circumstances.