The Pennsylvania Railroad Company v. Kittanning Iron & Steel Manufacturing Company case in 1919 revolved around a dispute over freight charges. The Kittanning Iron & Steel Manufacturing Co., the defendant, had been shipping goods via the Pennsylvania Railroad and was charged based on tariff rates filed with the Interstate Commerce Commission (ICC). However, they argued that these tariffs were unreasonable and sought to recover what it considered overpayments from the railroad company. The Supreme Court ruled in favor of the Pennsylvania Railroad Company stating that courts could not determine whether ICC-approved rates were reasonable or not; only Congress or ICC itself could make such determinations. This decision reinforced regulatory authority of administrative bodies like ICC and emphasized their role in setting fair market prices for public utilities.

In the dissenting opinion for Pennsylvania Railroad Company v. Kittanning Iron & Steel Manufacturing Company, Justice Holmes disagreed with the majority's decision that a railroad company could be held liable for damages caused by sparks from its locomotives setting fire to property near its tracks. He argued that this ruling contradicted previous decisions which had established that railroads were not responsible for such "inevitable" accidents unless negligence could be proven. Holmes contended that it was unreasonable to expect railroads to completely eliminate all risk of fires given their essential role in society and the inherent dangers associated with operating trains. Furthermore, he suggested that if property owners chose to locate their businesses close to railway lines, they should bear some responsibility for protecting against potential risks like fires sparked by passing trains.