The U.S. Supreme Court case Mills v. Lehigh Valley Railroad Company in 1914 revolved around a dispute over the interpretation of a contract between Naylor & Company and the railroad company regarding coal transportation rates. The plaintiff, Mills, as surviving partner of Naylor & Co., claimed that Lehigh Valley Railroad had breached their agreement by charging higher freight rates than what was stipulated in their contract. The defendant argued that they were justified due to an increase in operating costs caused by new legislation (the Hepburn Act). However, the court ruled against them stating that such changes should have been anticipated during negotiations and incorporated into the terms of their agreement if necessary. Therefore, it held that Lehigh Valley Railroad was liable for damages resulting from its breach of contract with Naylor & Co.

The dissenting opinion in the case of Mills v. Lehigh Valley Railroad Company argued that the majority's decision was incorrect because it failed to properly interpret and apply the law regarding negligence and liability. The dissent emphasized that, under existing legal principles, a party who negligently creates a dangerous situation should be held liable for any harm resulting from that danger, even if other factors also contributed to causing the harm. In this case, they believed that Lehigh Valley Railroad Company had acted negligently by leaving its cars unattended on an incline without proper brakes or safeguards in place - creating a foreseeable risk of them rolling down and causing damage - which is exactly what happened when one car rolled into Naylor & Co.'s property and caused significant damage. Therefore, they felt it was wrong for the majority to absolve Lehigh Valley Railroad Company of all liability simply because another company's employee (who did not know about these risks) may have accidentally set off this chain reaction by bumping into one car while trying to move his own train past them.