In the case of Johnson v. St. Louis, Iron Mountain and Southern Railway Company in 1891, the U.S Supreme Court ruled on a dispute involving railway freight charges. The plaintiff, Johnson, had shipped goods via the defendant's railway line but refused to pay for additional charges that were not included in their initial agreement. The defendant then held onto his goods as collateral until he paid these extra fees which led to this lawsuit by Johnson who claimed that they were unlawfully withholding his property. The court found in favor of the railroad company stating that it was within its rights to retain possession of goods until all transportation costs have been fully settled by the shipper according to common carrier laws at that time. This ruling affirmed railroads' right under common law lien principles allowing them to hold onto cargo if there are unpaid transport fees even if those fees weren't part of an original contract or estimate provided before shipment.

In the dissenting opinion for Johnson v. St. Louis, Iron Mountain and Southern Railway Company, it was argued that the majority's decision to uphold a lower court ruling in favor of the railway company was incorrect because it failed to consider key aspects of negligence law. The dissenting justices believed that there were significant questions about whether or not the railway company had acted negligently by failing to provide safe working conditions for its employees, including Mr. Johnson who suffered injuries while on duty due to an alleged unsafe environment created by his employer -the railway company-. They also disagreed with how evidence presented at trial had been interpreted and felt that more weight should have been given to testimony suggesting negligence on part of the defendant (railway). Furthermore, they expressed concern over potential implications this case could have on future labor cases involving worker safety issues if employers are not held accountable for maintaining safe work environments.