In the case of Rayonier Incorporated v. United States in 1956, the Supreme Court ruled that the U.S. government could be held liable for damages caused by negligence of its employees, overturning a previous decision which had granted immunity to federal agencies from such claims. The dispute arose when a fire allegedly started by an employee of the U.S Forest Service spread to lands owned by Rayonier Inc., causing significant damage. The company sued under the Federal Tort Claims Act (FTCA), arguing that if a private individual would be liable under state law then so should the government. Initially, lower courts dismissed their claim based on precedent stating that certain governmental functions were immune from liability due to their 'uniquely governmental' nature - in this case firefighting and prevention activities conducted on public land - but this was overturned by Supreme Court justices who found no basis for such distinctions within FTCA legislation.

In the dissenting opinion for Rayonier Incorporated v. United States, Justice Harlan argued that the majority's decision to hold the federal government liable under state tort law for negligence of its employees was a departure from established principles of sovereign immunity. He contended that this interpretation expanded governmental liability beyond what Congress intended when it passed the Federal Tort Claims Act (FTCA). According to him, such an expansion should be made by legislative action rather than judicial interpretation. Furthermore, he expressed concern about potential financial implications on public funds and possible hindrance in effective functioning of government agencies due to fear of litigation. Thus, he disagreed with the majority's ruling which held U.S Forest Service responsible for damages caused by a forest fire allegedly due to their negligence.