The Union Pacific Railroad Company v. Updike Grain Company and Crowell Lumber and Grain Company case in 1911 revolved around the issue of freight rates for interstate commerce. The plaintiff, Union Pacific Railroad Co., sued two grain companies alleging that they had been undercharged for shipping services due to a mistake by the railroad company's agent who applied an incorrect tariff rate. The defendants argued that they were not liable because they paid what was asked at the time of service without knowledge of any error on part of the railroad company. The Supreme Court ruled in favor of the defendants, stating that shippers cannot be held responsible for mistakes made by carriers regarding their own tariffs as long as there is no fraud or misrepresentation involved from shipper’s side.

The dissenting opinion in the case of Union Pacific Railroad Company v. Updike Grain Company and Crowell Lumber and Grain Company argued that the majority's decision was inconsistent with previous rulings on similar issues. The dissenters believed that the railroad company should not be held liable for damages caused by a fire started by sparks from one of its locomotives, as it had taken all reasonable precautions to prevent such an incident. They contended that holding companies responsible for accidents beyond their control would place an undue burden on businesses and could potentially stifle economic growth. Furthermore, they disagreed with the majority's interpretation of negligence law, arguing instead for a stricter standard requiring proof of recklessness or intentional wrongdoing rather than mere accident or misfortune.