In the 1953 case of Olberding, Doing Business as Vess Transfer Co., et al. v. Illinois Central Railroad Co., Inc., the U.S Supreme Court addressed a dispute over damages caused during transportation of goods. The plaintiffs, Olberding and Vess Transfer Company, had contracted with Illinois Central Railroad to transport a shipment of corn syrup from Louisiana to Ohio. However, upon arrival in Ohio it was discovered that some barrels were damaged due to leakage which occurred while in transit under the care of Illinois Central Railroad. The railroad company argued they should not be held liable for full damages because their contract contained a clause limiting liability unless negligence could be proven on their part - an argument rejected by lower courts who awarded full damages to Olberding and Vess Transfer Company based on federal law governing bills of lading (contracts for carriage). On appeal however, the Supreme Court reversed this decision finding that state laws allowing such limitation clauses were not preempted by federal legislation thus absolving Illinois Central Railroad from paying full compensation.

In the dissenting opinion for Olberding v. Illinois Central Railroad Co., Justice Jackson expressed concern over the majority's decision to allow a state court to exercise jurisdiction over an out-of-state defendant based solely on that defendant's "doing business" within the state. He argued that this interpretation of jurisdictional reach was overly broad and could potentially infringe upon constitutional protections against being haled into a distant or inconvenient forum without sufficient cause. Furthermore, he contended that such expansive view of personal jurisdiction might discourage interstate commerce by subjecting businesses to potential litigation in any state where they conduct operations, however minimal those operations may be. In his view, due process requires more than mere presence or doing business; it necessitates substantial connection between the defendant and the forum state.