In the 1913 case of Missouri Pacific Railway Company v. Larabee, the U.S Supreme Court ruled in favor of Larabee, a farmer whose land was damaged by fire caused by sparks from passing trains on adjacent railway lines owned and operated by Missouri Pacific Railway Company. The court held that even though there were no specific laws or regulations requiring spark arresters to be installed on locomotives at the time when they were built and put into service, it is still within reason for a company to take necessary precautions against known risks associated with its operations. Therefore, despite compliance with existing safety standards at the time of construction, failure to update equipment based on new knowledge could result in liability for damages caused as a result thereof. This ruling established an important precedent regarding corporate responsibility towards public safety.

In the dissenting opinion for Missouri Pacific Railway Company v. Larabee, it was argued that the court majority had erred in their interpretation of Kansas law and its application to this case. The dissent contended that under Kansas law, a railway company is not liable for damages caused by sparks from its locomotives unless negligence can be proven. They believed that there was no evidence presented to demonstrate such negligence on part of the Missouri Pacific Railway Company. Furthermore, they disagreed with the majority's view regarding 'reasonable use' of property and asserted that operating a railroad is indeed a reasonable use of property even if it occasionally causes damage through unavoidable accidents like fires sparked by locomotive operations. Therefore, according to them, without clear proof of negligence or intent to cause harm, holding the railway company responsible for fire damages was unjustified.