In the case of Missouri Pacific Railroad Co. v. Elmore & Stahl, the U.S Supreme Court ruled in favor of Elmore & Stahl, a Texas-based law firm that had sued Missouri Pacific Railroad for damages after a train collision resulted in loss and damage to goods they were transporting on behalf of their clients. The railroad company argued that it was not liable because the accident occurred due to an "act of God" - specifically heavy fog which reduced visibility. However, the court found that despite adverse weather conditions, there was evidence suggesting negligence by the train's crew who failed to take necessary precautions such as reducing speed or using signals effectively during poor visibility conditions. Therefore, it held that an act of God defense could not absolve them from liability if human error contributed significantly towards causing an accident.

In the dissenting opinion for Missouri Pacific Railroad Co. v. Elmore & Stahl, Justice Harlan argued that the Court had overstepped its bounds by interpreting Texas law in a way contrary to how Texas courts would likely interpret it. He contended that there was no clear precedent from Texas courts indicating they would apply their state's "filed rate" doctrine in this particular manner - to bar recovery of an overcharge even when the tariff filed with the Interstate Commerce Commission (ICC) was ambiguous and thus could not provide constructive notice of its terms. In his view, federal courts should abstain from making such determinations about state law unless absolutely necessary, especially given that ICC itself had found ambiguity in the tariff at issue here. Therefore, he disagreed with majority’s decision to deny relief based on their interpretation of state law rather than deferring to potential future decisions by Texas courts or allowing ICC determination regarding ambiguity play a role.