The U.S. Supreme Court case Pittsburgh, Cincinnati, Chicago & St. Louis Railway Company v. Fink in 1919 revolved around a dispute over the interpretation of an interstate commerce law related to freight transportation charges and liability for damage during transit. The plaintiff, Fink, had shipped goods via the defendant's railway company and claimed that his shipment was damaged due to negligence by the railway company while being transported from Ohio to Pennsylvania. He sought compensation based on rates outlined in a tariff filed with Interstate Commerce Commission (ICC). However, this tariff contained stipulations limiting carrier liability unless higher rates were paid for increased protection - which hadn't been done by Fink. The court ruled in favor of the railroad company stating that under federal law it could limit its own liability through tariffs filed with ICC if they are reasonable and just; provided shippers have options for different levels of protection at varying costs as per Carmack Amendment (an amendment regulating interstate common carriers). This decision reinforced railroads' ability to limit their liabilities through properly filed tariffs offering various rate structures corresponding with differing levels of responsibility.

In the dissenting opinion for Pittsburgh, Cincinnati, Chicago & St. Louis Railway Company v. Fink (1919), it was argued that the majority's decision to hold a railroad company liable for damages caused by sparks from its locomotives was unjust and inconsistent with previous rulings on similar cases. The dissenting justices contended that there were no specific regulations or laws requiring railroads to use spark arresters or other preventative measures at the time of the incident in question. They also pointed out that such fires are an inherent risk associated with railway operations and could not be entirely prevented even with reasonable care and precautions taken by railroad companies. Therefore, they believed it was unfair to impose liability on a company for damages resulting from an unavoidable hazard of their business operation unless negligence can be proven.