In the case of New Orleans & Northeastern Railroad Co. v. National Rice Milling Co., 1913, the Supreme Court was asked to determine whether a railroad company could be held liable for damages caused by delays in shipping goods, even if those delays were not directly attributable to negligence on the part of the railroad company. The National Rice Milling Company had sued for losses incurred when their rice shipments were delayed due to flooding that damaged railway tracks and bridges. The court ruled in favor of New Orleans & Northeastern Railroad Co., stating that while carriers are generally responsible for any damage or delay in transit under common law principles, they cannot be held accountable when such issues arise from circumstances beyond their control - like acts of God (natural disasters). This decision established an important precedent regarding carrier liability and force majeure clauses within contracts.

In the dissenting opinion for New Orleans & Northeastern Railroad Co. v. National Rice Milling Co., it was argued that the court majority erred in its interpretation of the Carmack Amendment, which governs liability for lost or damaged goods during interstate transport by railroads. The dissent maintained that under this amendment, a railroad company is liable as an initial carrier until delivery has been made to the consignee at destination, regardless of whether damage occurred on another line over which it had no control. This view holds that any contract attempting to limit such liability would be void and unenforceable because it contradicts federal law's intent to provide uniformity and certainty in rules governing transportation contracts across state lines. Therefore, according to this perspective, New Orleans & Northeastern Railroad should have been held responsible for damages incurred even if they happened while goods were transported by other carriers with whom they had agreements.