In the case of St. Louis, Iron Mountain & Southern Railway Company v. McWhirter (1912), the U.S Supreme Court ruled in favor of McWhirter, a landowner who sued the railway company for damages caused by fire to his property. The fire was allegedly started by sparks from one of the company's locomotives and spread across 180 acres of timberland owned by McWhirter. The court held that under Arkansas law, which applied in this case since it occurred within its jurisdiction, railroads were liable for fires ignited as a result of their operations regardless if negligence could be proven or not; they only needed to establish causation between railroad operation and damage incurred due to fire on plaintiff’s property. This ruling upheld an earlier decision made by lower courts awarding $1,000 in damages to McWhirter.

In the dissenting opinion for St. Louis, Iron Mountain & Southern Railway Company v. McWhirter, it was argued that the court majority misinterpreted Arkansas law regarding liability in railway accidents. The dissent contended that under Arkansas law, a railroad company could only be held liable if negligence on its part directly caused an accident and resulting injuries or death. In this case, there was no evidence of such direct causation; instead, the plaintiff's injury resulted from his own decision to jump off a moving train after mistakenly believing it had caught fire due to sparks seen flying from underneath one of the cars. Therefore, according to this interpretation of state law and principles of common-law negligence as understood by Justice Holmes (who penned the dissent), responsibility for any harm suffered should rest with those who acted recklessly or negligently - not those who merely provided an occasion for others' mistakes or misjudgments.