In the case of Great Northern Railway Company v. Steinke et al., 1922, the Supreme Court ruled in favor of Great Northern Railway Company. The dispute arose when a train owned by the railway company collided with an automobile at a crossing, resulting in injuries to occupants of the car and damage to both vehicles. The victims sued for damages claiming negligence on part of the railway company due to lack of adequate warning signals at that particular crossing point. The court held that while it was indeed unfortunate that such an accident occurred, there was no legal obligation for railroads to install specific types or numbers of safety devices at every railroad-highway intersection under federal law or North Dakota state law (where this incident took place). It further stated that although railroads have a duty towards public safety, they are not insurers against all accidents occurring on their property. Therefore, since there were no statutory requirements mandating certain warning devices be installed and because it could not be proven beyond reasonable doubt that absence thereof directly caused this mishap; henceforth any liability claims based solely upon these grounds were dismissed.

The dissenting opinion in the case of Great Northern Railway Company v. Steinke et al. argued that the majority's decision was inconsistent with previous rulings and failed to adequately consider relevant state laws. The dissent contended that, under Montana law, a railway company is liable for damages caused by fires started by its locomotives regardless of negligence or intent. They believed this principle should have been applied in this case as well, instead of ruling based on federal common law principles which require proof of negligence for liability to be established. Furthermore, they disagreed with the majority's interpretation of certain provisions within the Federal Safety Appliance Act and felt it did not preclude states from imposing stricter regulations on railroads operating within their borders.