In the case of Daniel Tod, Daniel P. Rhodes, Robert C. Yates and James Ford v Samuel F. Pratt and Edward P. Beals, the libellants sought to recover damages for injuries they sustained when their steamboat Sultana exploded in April 1865 near Memphis Tennessee while transporting Union soldiers home from Confederate prison camps at the end of the Civil War. The Supreme Court held that although there was evidence that negligence on behalf of Pratt and Beals had caused or contributed to cause an explosion which resulted in injury to passengers aboard Sultana, it could not be proven beyond a reasonable doubt due to lack of sufficient proof as required by law; thus no damages were awarded against them for any losses suffered by those injured or killed in this incident.

In the case of Daniel Tod, Daniel P. Rhodes, Robert C. Yates and James Ford v Samuel F. Pratt and Edward P. Beals, the dissenting opinion was that the libellants were not entitled to recover damages from their claim against steamboat Sultana for injuries sustained in an accident due to negligence on behalf of its owners or agents while they were passengers aboard it as there was no evidence presented that proved any such negligence had occurred at all during their voyage on board said vessel. The dissent argued that since none of the parties involved could prove beyond a reasonable doubt that either party had acted negligently then neither should be held liable for any damages incurred by those injured in this incident; thus ruling out any possibility of recovery for those who suffered injury due to this unfortunate event which took place upon Sultana's waters many years ago.