The U.S. Supreme Court case St. Louis and San Francisco Railway Company v. Stevenson in 1894 revolved around a dispute over land rights between the railway company and an individual named Stevenson. The railway company claimed that it had been granted certain lands by Congress under the Pacific Railroad Act of 1862, which was intended to encourage railroad construction across the United States. However, Stevenson argued that he held rightful ownership of these lands due to his homestead claim filed before the grant took effect on July 27th, 1870. The court ruled in favor of Stevenson stating that his homestead application gave him superior right to possession as compared with any subsequent claimant under a railroad grant from Congress made after such filing but prior to patenting or final proof for said homesteader's entry (i.e., completion). This decision upheld previous rulings asserting priority rights for settlers who file claims before congressional grants are issued.

In the dissenting opinion for St. Louis and San Francisco Railway Company v. Stevenson, it was argued that the majority's decision to hold the railway company liable for damages suffered by Stevenson due to a fire caused by sparks from one of its locomotives was incorrect. The dissenting justices believed that there wasn't sufficient evidence presented at trial proving beyond reasonable doubt that negligence on part of the railway company led directly to Stevenson's loss. They contended that while it is possible sparks from a passing train could have started the fire, other causes such as natural occurrences or human actions couldn't be ruled out conclusively based on provided evidence. Therefore, they felt holding the railroad responsible under these circumstances set an unfair precedent which might unduly burden railroads with liabilities arising from fires whose origins are uncertain but happen in proximity to their operations.