In the Southern Railway Company v. Burlington Lumber Company case of 1911, the Supreme Court examined a dispute over freight charges between a railway company and a lumber company. The Southern Railway Company sued Burlington Lumber for unpaid freight charges, while Burlington counterclaimed that they had been overcharged due to an incorrect classification of their goods by the railway. The court ruled in favor of the railroad company on both counts, stating that it was not within its jurisdiction to determine whether or not there had been an error in classifying goods for transportation purposes under Interstate Commerce Commission regulations. Furthermore, it held that any disputes regarding such classifications should be brought before the ICC itself rather than being litigated in court. This decision reinforced existing laws governing interstate commerce and emphasized regulatory authority as residing with administrative bodies like the ICC.

In the dissenting opinion for Southern Railway Company v. Burlington Lumber Company, it was argued that the majority's decision to hold a carrier liable for damages caused by its failure to provide cars in accordance with an agreement was incorrect. The dissenting justices believed that such agreements were not absolute promises but rather contingent upon availability and other factors beyond the control of carriers. They contended that holding carriers absolutely responsible would be unfair as they could not always predict or control circumstances like weather conditions, labor strikes, or mechanical failures which might prevent them from fulfilling their obligations under such agreements. Furthermore, they pointed out that there are regulatory bodies established specifically to handle disputes over transportation services and suggested these should have been utilized instead of resorting directly to litigation.