The U.S. Supreme Court case Pennsylvania Railroad Company v. Minds, Surviving and Liquidating Partner of Minds et al., Lately Trading as Bulah Coal Company in 1918 revolved around a dispute between the railroad company and a coal company over freight charges for transporting coal. The court had to decide whether the Interstate Commerce Act required railroads to charge shippers based on published rates or if they could negotiate lower prices privately with individual customers. The Pennsylvania Railroad argued that it was allowed to give discounts because it did not discriminate among its customers; all were offered the same opportunity for reduced rates if they shipped large quantities of goods over long distances. However, the Bulah Coal Company claimed this practice violated federal law by allowing some companies to pay less than others for identical services simply because they shipped more goods or used longer routes. In its decision, the Supreme Court sided with Bulah Coal Co., ruling that railroads must adhere strictly to their publicly posted tariffs without exception - even when offering volume-based discounts would be beneficial both for them and certain shippers.

In the dissenting opinion for Pennsylvania Railroad Company v. Minds, it was argued that the majority's decision to hold the railroad company liable for damages caused by a fire started by sparks from one of its locomotives was unjustified. The dissenting justices contended that there was insufficient evidence to prove negligence on part of the railroad company and thus, they should not be held responsible for losses incurred due to natural causes or unforeseeable accidents. They also disagreed with the interpretation of "presumption of negligence" in this case, arguing that such presumption should only apply when there is clear proof of carelessness or misconduct. Furthermore, they believed that holding companies accountable for damage caused without any fault would set a dangerous precedent and could potentially lead to an increase in unwarranted lawsuits against businesses.