In the Northern Pacific Railway Company v. Concannon case of 1915, the U.S Supreme Court ruled in favor of Northern Pacific Railway Company. The dispute arose when John Concannon filed a lawsuit against the railway company for damages caused by a fire that he claimed was started by sparks from one of their locomotives. However, there was no direct evidence to prove this claim and it relied heavily on circumstantial evidence such as wind direction and proximity to train tracks. The court held that while circumstantial evidence could be used to establish facts, it must do more than merely coincide with them or raise suspicion; it should reasonably lead to those conclusions without assuming other equally probable causes. Therefore, due to lack of substantial proof linking the fire directly to the railway's operations, judgement was given in favor of Northern Pacific Railway Company.

The dissenting opinion in the case of Northern Pacific Railway Company v. Concannon argued that the majority's decision to uphold a state law requiring railroads to maintain fences along their tracks was an overreach of federal power. The dissenters believed that this issue should be left up to individual states, rather than being mandated by the federal government. They also disagreed with the majority's interpretation of interstate commerce laws, arguing that these laws were not intended to regulate local matters such as fencing requirements for railways. Furthermore, they contended that enforcing such regulations would place an undue burden on railway companies and could potentially hinder their ability to conduct business effectively.