In the case of St. Louis Dressed Beef and Provision Company v. Maryland Casualty Company, 1905, the Supreme Court was tasked with determining whether a fire insurance policy covered losses caused by an explosion in a refrigeration plant owned by the plaintiff company. The defendant insurer argued that it did not cover such damages as they were not explicitly mentioned in their policy agreement. However, the court ruled in favor of St. Louis Dressed Beef and Provision Company stating that although explosions weren't specifically listed under covered perils within their contract, it fell under "other perils" or "misfortunes". Therefore, since there was no explicit exclusion for damage from explosions in the insurance contract's language and considering its comprehensive nature to protect against loss due to physical damage to property from any external cause unless expressly excluded - this meant that losses incurred due to an explosion should be compensated by Maryland Casualty Company.

The dissenting opinion in the case of St. Louis Dressed Beef and Provision Company v. Maryland Casualty Company argued that the insurance policy should cover all losses, including those caused by employee dishonesty or theft. The justice disagreed with the majority's interpretation of the contract language, asserting that it was too narrow and did not fully consider common business practices or risks at that time period. They believed that a broader interpretation would have been more consistent with both parties' expectations when they entered into this agreement, as well as being more equitable overall given these circumstances.