In the Union Pacific Railway Company v. Daniels case of 1893, the U.S Supreme Court ruled in favor of Union Pacific Railway Company. The dispute arose when Mr. Daniels claimed that his land was wrongfully included within the limits of a land grant made by Congress to aid in constructing a railroad and telegraph line from Missouri River to California's Pacific coast. He sought compensation for damages caused by alleged trespassing on his property by the railway company during construction work. However, it was found that at the time Congress approved this project, Mr.Daniels had not yet acquired rights to said property; hence he could not claim any damages or compensation as such lands were rightfully granted to Union Pacific under Congressional approval before Daniel’s acquisition.

In the dissenting opinion for Union Pacific Railway Company v. Daniels, Justice Brewer argued that the court majority had erred in its interpretation of the law and its application to this case. He believed that a railroad company should be held responsible for damages caused by fires started by sparks from their locomotives, even if they were not negligent or at fault. This was based on his view that railroads are inherently dangerous operations and thus should bear strict liability for any harm they cause. Furthermore, he disagreed with the majority's assertion that there was no precedent supporting such a ruling; instead pointing out several state cases where courts had imposed similar liabilities on railway companies under common law principles of nuisance and trespassing.