In the case of Louisville & Nashville Railroad Company v. Rice in 1917, the U.S Supreme Court ruled in favor of the railroad company. The dispute arose when a train owned by Louisville & Nashville Railroad Company collided with a wagon driven by Rice at an unguarded crossing, resulting in injuries to Rice and damage to his property. He sued for damages on grounds that negligence was involved as there were no warning signals or guards present at the crossing where he had been hit. However, it was found that despite this absence of warnings or guards, which might have constituted negligence under some circumstances, it did not apply here because Rice knew about the dangerous nature of this particular crossing from previous experiences and still chose to cross without taking necessary precautions himself. Therefore, his own contributory negligence barred him from recovering any damages according to Alabama state law applicable then.

In the dissenting opinion for Louisville & Nashville Railroad Company v. Rice, it was argued that the court majority had erred in its interpretation of Alabama state law and misapplied federal principles regarding interstate commerce regulation. The dissent contended that under Alabama law, a railroad company could be held liable for damages caused by sparks from its locomotives if proper spark arresters were not used or maintained. It further asserted that this state-level liability did not conflict with federal regulations on interstate railroads as claimed by the majority opinion because those regulations did not specifically address spark arrester maintenance. Therefore, according to the dissenting justices, there should have been no preemption of state law in this case and thus no reason to overturn previous judgments against the railroad company.