In the case of Male, Trustee for Chapin v. Atchison, Topeka & Santa Fe Railway Company (1915), the U.S Supreme Court ruled in favor of the railway company. The dispute arose when a train owned by Atchison, Topeka & Santa Fe Railway Company collided with another train that was parked on a siding near Raton, New Mexico due to negligence from one of its employees. As a result of this collision, several cars were damaged including those leased by Mr. Chapin's trustee - Mr. Male who sought compensation for damages incurred during transportation under an interstate bill of lading contract between them and the railway company. The court held that while it is true that carriers are liable for damage caused by their own negligence or fault under common law principles; however they can limit their liability through special contracts as long as these agreements do not exempt them from all responsibility or violate public policy considerations. Therefore since there was no evidence suggesting any violation against public policy in this particular agreement and considering that both parties had equal bargaining power at time they entered into contract; thus it would be unjust to hold carrier responsible beyond what has been agreed upon within terms stipulated in said contract.

In the dissenting opinion for Male, Trustee for Chapin v. Atchison, Topeka & Santa Fe Railway Company (1915), it was argued that the majority's ruling contradicted established legal principles regarding property rights and obligations. The dissenting justices believed that a railway company should not be held liable for damages to adjacent properties caused by sparks from its locomotives if those properties were not part of its right-of-way or otherwise under its control. They contended that such liability would unfairly burden railway companies with responsibilities beyond their reasonable scope and could potentially discourage economic development by making rail transportation more costly and risky. Furthermore, they asserted that landowners have an obligation to take reasonable precautions against known risks like fire sparks from passing trains, especially when those risks are inherent in activities (like railroad operation) deemed beneficial or necessary for society as a whole.