The U.S. Supreme Court case Mexican Central Railway Company, Limited v. Duthie in 1902 revolved around a dispute over the delivery of goods and subsequent damages claimed by the plaintiff, Duthie. The railway company was contracted to transport machinery from Boston to Chihuahua, Mexico for Duthie but failed to deliver it at the agreed time causing significant financial loss for him. The court had to determine whether or not an international carrier could limit its liability through contract stipulations when it comes to delays in transportation that result in damage or loss of goods beyond their control due to unforeseen circumstances such as strikes or insurrections (force majeure). In this case, there were two contracts involved: one between Boston and El Paso under American law which limited liability; another between El Paso and Chihuahua under Mexican law with no limitation on liability clause included. Ultimately, the Supreme Court ruled against the railway company stating that they couldn't limit their responsibility for losses incurred during transit unless explicitly stated within both contracts covering all parts of journey.

In the dissenting opinion for Mexican Central Railway Company, Limited v. Duthie, Justice Harlan argued that the majority's decision was inconsistent with previous rulings and principles of international law. He contended that a corporation doing business in multiple countries should be considered a citizen of each country for jurisdictional purposes. In this case, he believed that because the railway company had substantial operations in both Mexico and Massachusetts, it should be treated as a citizen of both places under U.S law. Therefore, according to him, federal courts would have jurisdiction over disputes involving such corporations even if they were incorporated abroad. This view contrasted sharply with the majority's ruling which held that only place of incorporation determines corporate citizenship for diversity jurisdiction purposes.