In the 1904 case of Leonard v. Vicksburg, Shreveport and Pacific Railroad Company, the U.S Supreme Court ruled in favor of the defendant, a railroad company. The plaintiff was an employee who had been injured while working for the company and sought compensation for his injuries. However, he had signed a contract with his employer that exempted them from liability in such cases unless negligence could be proven on their part. The court held that this agreement did not violate any public policy or law as it only required employees to assume ordinary risks associated with their jobs which they were aware of when signing contracts. Therefore, since there was no evidence presented showing negligence by the railroad company leading to Leonard's injury, he wasn't entitled to damages under this agreement.

In the dissenting opinion for Leonard v. Vicksburg, Shreveport and Pacific Railroad Company, it was argued that the majority's decision to hold a railroad company liable for damages caused by sparks from its locomotive was unjustified. The dissenting justices contended that there were no laws or regulations in place at the time of the incident requiring railroads to equip their trains with spark arresters or other devices designed to prevent such accidents. They also pointed out that even if such equipment had been used, it might not have prevented this particular accident due to unforeseen circumstances like wind direction and intensity. Therefore, they believed holding the railroad company responsible under these conditions would set an unfair precedent of strict liability regardless of reasonable precautions taken by companies against potential risks associated with their operations.