In the 1925 case Turner, Dennis & Lowry Lumber Company v. Chicago, Milwaukee & St. Paul Railway Company, the U.S Supreme Court ruled in favor of the railway company. The lumber company had sued for damages after a fire broke out on their property due to sparks from one of the railway's locomotives. However, it was found that there were no federal regulations requiring spark arresters on trains at that time and thus no negligence could be attributed to the railroad company under federal law or Interstate Commerce Commission rules. Furthermore, while Minnesota state law did require such devices, this regulation was deemed not applicable as it interfered with interstate commerce which is governed by Congress under the Constitution's Commerce Clause.

In the dissenting opinion for Turner, Dennis & Lowry Lumber Company v. Chicago, Milwaukee & St. Paul Railway Company (1925), it was argued that the majority's decision to uphold a lower court ruling in favor of the railway company was incorrect. The dissenting justices believed that there were significant factual errors and misinterpretations of law in the original trial which should have led to a reversal or at least remand for retrial. They contended that Turner, Dennis & Lowry Lumber Co., as shippers who had suffered damages due to alleged negligence by the railway company, had presented sufficient evidence to support their claim and deserved compensation under existing laws governing interstate commerce and transportation liability. The dissenters also disagreed with how certain legal principles related to burden of proof and negligence were applied in this case.