The Southern Railway Company v. Carnegie Steel Company case in 1899 revolved around a dispute over freight charges for the transportation of iron and steel products. The Southern Railway Company sued Carnegie Steel, claiming that they had underpaid for their services based on rates established by the Interstate Commerce Commission (ICC). However, Carnegie Steel argued that these rates were not applicable as they were set after the shipment was made. The U.S Supreme Court ruled in favor of Carnegie Steel stating that ICC's rate changes could not be applied retroactively to past transactions unless explicitly stated otherwise. Therefore, any shipments made before such changes are subject to previous tariff agreements between parties involved.

In the dissenting opinion for Southern Railway Company v. Carnegie Steel Company, it was argued that the majority's decision to hold a railway company liable for damages caused by an accident during transportation of goods was incorrect. The dissenting justices believed that the contract between the two parties clearly stated that any risk associated with transporting goods would be borne by the shipper, in this case, Carnegie Steel Company. They contended that such contracts were not uncommon and were often used to reduce shipping costs for shippers who agreed to assume responsibility for potential accidents or damage during transit. Therefore, they opined that since both parties willingly entered into this agreement understanding its terms and conditions, it should have been upheld by court rather than making Southern Railway bear all losses resulting from an unforeseen accident which was beyond their control.