In the case of Lake Shore & Michigan Southern Railway Company v. Prentice, 1892, the U.S Supreme Court ruled in favor of Lake Shore & Michigan Southern Railway Company. The dispute arose when Mr. Prentice sued the railway company for damages after he was injured while riding on one of their trains due to a collision caused by negligence from an employee at another railroad company that shared tracks with Lake Shore. However, his ticket contained a clause exempting Lake Shore from liability for accidents caused by other companies using its track under contract or agreement. The court held that such contractual limitations were not against public policy and did not absolve carriers from responsibility for their own negligence or misconduct but merely limited liability arising out of joint use agreements with other railroads. Therefore, it was determined that Mr. Prentice could not recover damages as per the terms stated on his ticket.

In the dissenting opinion for Lake Shore & Michigan Southern Railway Company v. Prentice, Justice Brewer argued that the majority's decision to uphold a state law requiring railroads to pay damages for livestock killed on their tracks was an unconstitutional interference with interstate commerce. He contended that such laws could potentially disrupt and burden interstate trade by imposing different obligations and liabilities in each state through which a railroad passed. Furthermore, he believed it was unfair to hold railroads solely responsible for accidents involving livestock when farmers also had a duty to prevent their animals from straying onto train tracks. In his view, this ruling unfairly singled out one industry (railways) while ignoring the responsibilities of another (agriculture).