In the 1892 case of Keels v. Central Railroad Company, the U.S Supreme Court ruled in favor of the defendant, Central Railroad Company. The plaintiff, Keels had sued for damages after his cotton was destroyed by fire while stored in a warehouse owned by the railroad company. He alleged that it was due to negligence on part of the company's employees which led to this incident. However, upon review and consideration of evidence presented during trial proceedings at lower courts, it was found that there were no grounds to prove negligence or misconduct from any employee under service with Central Railroad Company at time when said fire occurred. Furthermore, as per terms agreed between both parties prior to storage arrangement being made official - all liability risks associated with storing goods inside warehouse premises were assumed solely by owner (Keels). Therefore based on these findings and agreement conditions set forth earlier; court decided against awarding any compensation towards plaintiff’s loss claim.

In the dissenting opinion for Keels v. Central Railroad Company, it was argued that the majority's decision to hold the railroad company liable for damages caused by a fire started unintentionally by one of its locomotives was incorrect. The dissenting justices believed that there should be no liability without fault and pointed out that there was no evidence suggesting negligence on part of the railroad company. They contended that accidents can happen even when all due care has been taken, and in such cases, it is unjust to place financial responsibility on parties who were not at fault. Furthermore, they expressed concern about setting a dangerous precedent where companies could be held accountable for uncontrollable events or circumstances beyond their control which may lead to an increase in litigation against businesses operating with utmost caution and diligence.