In the case of Keokuk & Hamilton Bridge Company v. Salm et al., 1921, the U.S Supreme Court was tasked with determining whether a bridge company could be held liable for damages caused by ice flows resulting from its bridge piers. The plaintiffs were owners of riverfront property and claimed that the placement of these piers had altered the natural flow of ice downriver, causing damage to their properties during winter months. They sought compensation for this alleged harm. The court ruled in favor of Keokuk & Hamilton Bridge Company, stating that they could not be held responsible as there was no negligence on their part in constructing or maintaining the bridge and its piers. It further noted that any alteration to nature's course due to human intervention is inevitable when progress demands it; therefore, unless such alterations are negligently made or maintained leading directly to injury or damage, liability cannot be imposed.

In the dissenting opinion for the case of Keokuk & Hamilton Bridge Company v. Salm et al., it was argued that the majority's decision to uphold a lower court ruling, which held that a bridge company could be sued in any state where it does business, was incorrect and inconsistent with previous rulings. The dissenting justices believed this interpretation expanded jurisdiction too broadly and unfairly burdened businesses by potentially subjecting them to litigation in numerous states simultaneously. They contended that just because a corporation conducts business within a state does not automatically mean they are present there for legal purposes or should be subjected to its courts' jurisdiction. Instead, they suggested limiting jurisdiction over corporations to their home state or where they have significant operations or assets. This perspective emphasized fairness towards corporations and consistency with past precedents on corporate presence and liability.