In the case of Jamestown and Northern Railroad Company v. Jones, 1899, the U.S Supreme Court ruled in favor of Jones. The dispute arose when a fire broke out from sparks emitted by one of Jamestown and Northern Railroad's locomotives, damaging Jones' property. The railroad company argued that they were not liable for damages as there was no negligence on their part; it was an unavoidable accident due to the nature of steam engines at that time which occasionally discharged sparks capable of starting fires. However, under North Dakota law (where the incident occurred), railroads were held responsible for any damage caused by fires started by their locomotives unless they could prove "extraordinary care" had been taken to prevent such incidents - a burden which Jamestown & Northern failed to meet according to lower courts' findings upheld by this decision.

In the dissenting opinion for Jamestown and Northern Railroad Company v. Jones, the justice argued that the plaintiff should not be allowed to recover damages because he had willingly assumed risk by working in a dangerous environment. The justice believed that it was unreasonable to hold employers liable for accidents when their employees were fully aware of potential dangers but chose to work anyway. He also pointed out inconsistencies in how liability laws were applied across different industries, arguing that railroad companies seemed to face harsher penalties than others. Furthermore, he contended that this case could set a dangerous precedent where businesses would be discouraged from operating due to fear of litigation costs associated with workplace accidents.