In the Southern Pacific Co. v. Gileo et al., 1955, the Supreme Court of the United States ruled in favor of Southern Pacific Company, reversing a previous decision by an Arizona court that had awarded damages to Gileo and other respondents for livestock loss caused by a fire allegedly started by one of Southern Pacific's locomotives. The Supreme Court held that there was insufficient evidence to prove negligence on part of the railway company as required under Arizona law which stipulates that proof must be provided beyond mere speculation or conjecture. The ruling emphasized that while it is possible for sparks from a passing train to start fires, this alone does not establish liability unless specific negligent conduct can be demonstrated.

In the dissenting opinion for Southern Pacific Co. v. Gileo et al., Justice Frankfurter disagreed with the majority's ruling that a railroad company could be held liable for injuries sustained by an employee who was not directly involved in interstate commerce at the time of his accident, but whose work generally contributed to such commerce. He argued that this interpretation extended federal jurisdiction too far and blurred the distinction between state and federal power over local activities related to interstate commerce. The justice believed that Congress did not intend for its laws protecting railway workers to apply so broadly, as it would lead to excessive litigation against railroads and potentially undermine their financial stability. He also expressed concern about potential inconsistencies in applying these laws if they were interpreted differently from case-to-case or court-to-court.