In the 1943 case of Midstate Horticultural Co., Inc. v. Pennsylvania Railroad Co., the United States Supreme Court ruled in favor of the Pennsylvania Railroad Company, reversing a decision by the lower court that had awarded damages to Midstate Horticultural for losses incurred due to delays in shipping perishable goods. The Supreme Court held that under federal law governing interstate commerce and transportation, specifically the Carmack Amendment to Interstate Commerce Act, a shipper must file a claim with carrier within stipulated time period mentioned on bill of lading (a detailed list of shipment). In this case, Midstate failed to comply with this requirement which resulted in forfeiture of its rights for damage claims against railroad company. This ruling emphasized importance placed by courts on procedural compliance when seeking remedies under federal laws regulating commercial activities.

In the dissenting opinion for the case of Midstate Horticultural Co., Inc. v. Pennsylvania Railroad Co., it was argued that the majority's decision failed to adequately consider and apply established principles of contract law, particularly those relating to mutual assent and consideration. The dissenting justices believed that there was no valid contract between Midstate Horticultural Company and Pennsylvania Railroad because there wasn't a clear meeting of minds or an exchange of value as required by traditional contract theory. They also disagreed with the majority's interpretation of relevant federal statutes, arguing that these laws were not intended to override basic contractual requirements or provide special protections for shippers in their dealings with railroads. In essence, they felt that the court had overstepped its bounds by intervening in what should have been a private contractual dispute resolved through normal legal channels.