In the case of Pennsylvania Railroad Company v. Keystone Elevator and Warehouse Company in 1914, the Supreme Court ruled on a dispute involving property rights and railway access. The Keystone Elevator and Warehouse Company owned a grain elevator that was serviced by tracks belonging to the Pennsylvania Railroad. When the railroad company decided to remove these tracks, Keystone sued for an injunction to prevent this action, arguing that it would cause irreparable harm to their business operations. However, the court found in favor of Pennsylvania Railroad Co., ruling that they had no obligation under common law or statute law to maintain serviceable track connections with private industries such as warehouses or elevators unless there was a specific contract obligating them otherwise.

The dissenting opinion in the case of Pennsylvania Railroad Company v. Keystone Elevator and Warehouse Company argued that the majority's decision was incorrect because it failed to properly consider the rights of both parties involved. The dissenting justices believed that, while a railroad company has an obligation to serve public interests, this does not mean they should be forced into contracts or agreements against their will or best interest. They contended that forcing such obligations on companies could potentially lead to abuse by those who would take advantage of these imposed duties for personal gain at the expense of others' rights and freedoms. Furthermore, they expressed concern over potential negative impacts on commerce if railroads were compelled into service without consideration for reasonable compensation or terms beneficial to them as well as customers.