In the 1914 case Meeker, Surviving Partner of Meeker & Company v. Lehigh Valley Railroad Company, the U.S Supreme Court ruled in favor of Lehigh Valley Railroad Company. The dispute arose when Meeker & Co., a coal company, claimed that Lehigh Valley had violated antitrust laws by giving preferential rates to another coal company and thus creating unfair competition. However, the court found no evidence supporting this claim as there was no proof that these alleged discriminatory practices resulted in any harm or damage to Meeker's business operations or profits. Furthermore, it was determined that even if such discrimination did occur, it would be an issue for regulatory bodies like Interstate Commerce Commission (ICC) rather than courts since ICC has been specifically tasked with overseeing railroad rate disputes under federal law.

In the dissenting opinion for Meeker v. Lehigh Valley Railroad Company, Justice Holmes disagreed with the majority's decision that a railroad company could not be held liable for damages caused by its failure to deliver goods on time due to an unforeseen strike. He argued that the contract between Meeker & Company and Lehigh Valley Railroad did not explicitly exempt the latter from liability in such circumstances. Furthermore, he contended that even if there was an implied understanding of potential delays due to strikes or similar events, it should not absolve a carrier of all responsibility when they have accepted payment for services rendered. According to Holmes, accepting money under these conditions implies a guarantee of performance regardless of difficulties encountered unless specifically stated otherwise in their agreement.