The United States Supreme Court case, UNITED STATES et al. v. ATLANTA, BIRMINGHAM & COAST RAILROAD COMPANY in 1930 revolved around the issue of whether or not a railroad company could be held liable for damages to goods during transit if they were caused by an "Act of God". The Atlanta, Birmingham & Coast Railroad Company had been contracted to transport a shipment of bananas from New Orleans to Atlanta but due to an unexpected and severe cold weather event (an Act of God), the bananas froze and became unsellable. The court ruled that despite this being an unforeseen natural event beyond human control, the railroad company was still responsible for ensuring safe delivery under their contract with the shipper. Therefore, it was decided that they were indeed liable for damages incurred as a result of failing to deliver goods in sellable condition regardless of external circumstances.

In the dissenting opinion for the case of UNITED STATES et al. v. ATLANTA, BIRMINGHAM & COAST RAILROAD COMPANY, Justice Stone argued that the Interstate Commerce Commission (ICC) had overstepped its bounds by ordering a reduction in intrastate freight rates without sufficient evidence to justify such action. He contended that while it was within ICC's power to ensure uniformity and fairness in interstate commerce, this did not extend to arbitrarily lowering intrastate rates based on an assumption of unreasonableness or discrimination against interstate commerce. The burden of proof should be on ICC to demonstrate specific instances where these issues occur before taking corrective measures. Furthermore, he pointed out that states have their own regulatory bodies capable of addressing any unfair practices within their jurisdiction; hence federal intervention is unnecessary unless there is clear evidence showing failure at state level regulation.