In the 1912 case of St. Louis, Iron Mountain & Southern Railway Company v. Edwards, the U.S Supreme Court ruled in favor of Edwards, a passenger who was injured while traveling on one of the railway company's trains. The court held that as a common carrier engaged in interstate commerce, the railway company had an obligation to provide safe transportation for its passengers and could not absolve itself from liability through contractual agreements or ticket stipulations stating otherwise. This decision reinforced that public service companies cannot contract away their duty to exercise reasonable care towards customers' safety.

In the dissenting opinion for St. Louis, Iron Mountain & Southern Railway Company v. Edwards, Justice Holmes disagreed with the majority's decision to uphold a state law that allowed double damages against railroads for livestock killed on un-fenced tracks. He argued that this law was an unconstitutional interference with interstate commerce because it placed an undue burden on out-of-state businesses and favored local interests over national ones. Furthermore, he contended that such laws should be evaluated based on their practical impact rather than their formal language or stated purpose - in this case, he believed the effect of the law was discriminatory even if its text did not explicitly discriminate against out-of-state companies. Lastly, Justice Holmes expressed concern about states having too much power to regulate industries crucial to national economy like railroads without federal oversight.