In the 1913 case of Santa Fe Central Railway Company v. Friday, the U.S. Supreme Court ruled in favor of Friday, a rancher who sued the railway company for damages after his cattle were killed by trains on multiple occasions. The court held that it was not enough for railroads to simply fence their tracks; they also had an obligation to maintain those fences and ensure they effectively kept livestock out. This ruling established that railroad companies could be held liable if their negligence led to damage or loss for others - even if unintentional or indirect - setting a precedent in tort law regarding corporate responsibility and liability.

In the dissenting opinion for Santa Fe Central Railway Company v. Friday, it was argued that the railway company should not be held liable for damages caused by a fire started by one of its locomotives. The dissenting justices believed that there was insufficient evidence to prove negligence on part of the railroad company and thus, they shouldn't be held responsible for any damage caused by sparks from their engines unless it can be proven beyond reasonable doubt that they failed in their duty to equip and maintain their locomotives properly so as to prevent such occurrences. They also contended that even if some degree of carelessness could have been established, this did not automatically mean liability since fires are common incidents associated with running trains and do not necessarily indicate neglect or misconduct.