In the 1928 case of Michigan Central Railroad Company v. Mix et al., the U.S. Supreme Court ruled in favor of Michigan Central Railroad Company, reversing a decision by the Supreme Court of Michigan. The dispute arose when several employees sued for overtime pay under an existing law that required railroads to compensate workers at one and a half times their regular rate for any work over eight hours per day or forty hours per week. However, this law had been repealed before these claims were made but after the work was performed. The court held that repealing legislation does not affect rights accrued or liabilities incurred under previous laws unless expressly stated otherwise in its provisions or implied by necessary implication from its terms; therefore, it did not apply retroactively to negate obligations arising during its existence even if they were asserted afterwards through litigation.

In the dissenting opinion for Michigan Central Railroad Company v. Mix et al., the justice disagreed with the majority's ruling that a railroad company could be held liable for damages caused by sparks from its locomotives, even if it had taken all reasonable precautions to prevent such incidents. The dissent argued that this interpretation of liability was overly broad and unfair to railroad companies, as it essentially made them insurers against any possible harm their operations might cause, regardless of fault or negligence on their part. This would place an undue burden on these businesses and potentially hinder economic growth and development. Furthermore, they contended that such strict liability should only apply in cases where there is clear evidence of negligence or misconduct by the company involved.