In the case of Swift & Company v. Hocking Valley Railway Company in 1916, the U.S Supreme Court ruled that a railway company could not be held liable for damages caused by a delay in shipping goods unless it was proven that the delay was unreasonable and resulted from negligence or failure to provide adequate service. The court's decision overturned an earlier ruling which had awarded damages to Swift & Co., a meatpacking firm, who claimed they suffered losses due to delays in transporting their products by Hocking Valley Railway. The Supreme Court found no evidence of negligence on part of the railway company nor any contractual obligation specifying time-bound delivery. Therefore, it concluded that mere loss resulting from late delivery did not entitle Swift & Co. to compensation unless there was proof of unreasonable delay attributable directly to actions or omissions by Hocking Valley Railway.

The dissenting opinion in the case of Swift & Company v. Hocking Valley Railway Company argued that the majority's decision to allow Swift & Co. to sue for damages was incorrect because it ignored established principles of law regarding interstate commerce and contracts between private parties. The dissent emphasized that a railway company, as a common carrier engaged in interstate commerce, is subject to federal regulation and cannot be held liable for damages resulting from its compliance with such regulations. Furthermore, they contended that any contract between Swift & Co. and the railway should not supersede these regulatory obligations or grant additional rights beyond those provided by law. They also expressed concern about potential negative implications of this ruling on future cases involving similar disputes between shippers and carriers.