The U.S. Supreme Court case Pennsylvania Railroad Company v. Clark Brothers Coal Mining Company in 1914 revolved around a dispute over freight charges for coal shipments. The Clark Brothers Coal Mining Company sued the Pennsylvania Railroad, claiming that it had been overcharged by the railroad company and was entitled to repayment of excessive rates under the Interstate Commerce Act. The lower courts ruled in favor of Clark Brothers, but on appeal, the Supreme Court reversed this decision. It held that while railroads could not charge unreasonable rates, shippers like Clark Brothers were also required to challenge those rates before they paid them through an administrative process with the Interstate Commerce Commission (ICC). Since Clark Brothers did not do so and instead directly filed a lawsuit against Pennsylvania Railroad after payment, their claim was dismissed.

In the dissenting opinion for Pennsylvania Railroad Company v. Clark Brothers Coal Mining Company, it was argued that the railroad company should not be held liable for damages caused by a fire sparked by one of its locomotives. The dissenting justices believed that there was insufficient evidence to prove negligence on part of the railroad company and emphasized that fires are an inherent risk associated with operating steam locomotives. They also pointed out that coal mining companies such as Clark Brothers should reasonably expect this risk when choosing to locate their operations near railway lines. Furthermore, they disagreed with the majority's interpretation of "negligence" in this context, arguing instead for a stricter definition which would require proof of carelessness or failure to take reasonable precautions against foreseeable risks.