In the case of Hartford Fire Insurance Company v. Chicago, Milwaukee & St. Paul Railway Company in 1899, the U.S Supreme Court ruled on a dispute involving an insurance claim for damages caused by fire to a railway company's property. The Hartford Fire Insurance Company had refused to pay out on its policy with the Chicago, Milwaukee & St. Paul Railway Company after it was discovered that employees of the railway company had started the fire negligently while attempting to thaw frozen water pipes using open-flame torches without taking necessary precautions against potential fires. The court held that such negligence did not absolve Hartford from their obligation under their insurance contract and ordered them to honor their commitment and compensate for losses incurred due to this incident as per terms agreed upon in their policy.

In the dissenting opinion for Hartford Fire Insurance Company v. Chicago, Milwaukee & St. Paul Railway Company, Justice Harlan argued that the majority's interpretation of the Interstate Commerce Act was too broad and could potentially lead to abuses of power by federal courts. He contended that while Congress had indeed intended to regulate interstate commerce through this act, it did not intend for all matters related to such commerce - including those involving purely local affairs or private contracts - to fall under federal jurisdiction. In his view, allowing federal courts such extensive authority would undermine states' rights and upset the balance between state and national powers as established by the Constitution. Furthermore, he believed that interpreting any contract dispute with potential effects on interstate commerce as a matter of public interest subject to regulation would unduly expand government control over private business transactions.