In the 1930 case Lewis-Simas-Jones Co. v. Southern Pacific Co., the United States Supreme Court ruled on a dispute involving transportation charges for goods shipped by rail. The plaintiff, Lewis-Simas-Jones Company, had contracted with Southern Pacific Company to transport its goods but later refused to pay the full amount of freight charges due to alleged overcharges and discriminatory rates by Southern Pacific. The lower court initially sided with Lewis-Simas-Jones, ruling that they were entitled to reparation for these overcharges under federal law (the Interstate Commerce Act). However, upon appeal from Southern Pacific, the Supreme Court reversed this decision stating that there was no evidence of discrimination or violation of any provision in their contract or tariff schedules filed with Interstate Commerce Commission (ICC). Therefore, it held that ICC's jurisdiction did not extend into disputes about contractual obligations unless there is clear proof of unreasonable practices or violations.

The dissenting opinion in the case of Lewis-Simas-Jones Co. v. Southern Pacific Co., argued that the majority's decision to uphold a lower court ruling, which found Southern Pacific Company not liable for damages incurred by Lewis-Simas-Jones Company during transportation, was incorrect. The dissent contended that the carrier had an absolute duty to safely transport goods and should be held accountable for any damage or loss occurring during transit unless it could prove negligence on part of shipper or other exceptions recognized by law. They believed that there were no such exceptions applicable in this case and hence, liability should have been imposed on Southern Pacific Company as per common-law rules governing carriers' responsibility towards shippers' property.