In the 1917 case of Salt Lake Investment Company v. Oregon Short Line Railroad Company, the Supreme Court was asked to determine whether a railroad company could be held liable for damages caused by sparks from its locomotives setting fire to nearby property. The Salt Lake Investment Company owned land in Utah that had been damaged by such fires and sought compensation from the Oregon Short Line Railroad Company. However, at issue was an 1888 statute which absolved railroads of liability for such damage unless it could be proven that they were negligent or failed to use spark arresters on their engines. The court ruled in favor of the railroad company, stating that there was no evidence presented proving negligence on their part nor any proof showing failure to use spark arresters as required by law. Therefore, under existing legislation, they couldn't be held responsible for damages caused due to these fires.

In the dissenting opinion for Salt Lake Investment Company v. Oregon Short Line Railroad Company, it was argued that the majority's decision to uphold a lower court ruling in favor of the railroad company was incorrect. The dissenting justices believed that there were significant factual errors and misinterpretations of law in the original trial which should have led to its reversal on appeal. They contended that Salt Lake Investment Co., as a bona fide purchaser, had acquired valid title to certain lands under an 1869 Act granting land rights to railroads, despite later claims by Oregon Short Line Railroad Co. This view held that any subsequent conveyance or mortgage by OSL did not affect SLIC's rights because they were protected under federal statute at time of their purchase - before OSL received patent from government or made any claim against these lands. Therefore, according to this perspective, SLIC should have been recognized as rightful owner and allowed recovery for damages resulting from wrongful possession by OSL.