In the case of United States v. Chesapeake & Ohio Railway Co., 1956, the U.S. Supreme Court was asked to decide whether a railroad company could be held liable for damages caused by sparks from one of its locomotives igniting and destroying property owned by another party. The court ruled in favor of the railway company, stating that it could not be held responsible unless negligence on its part could be proven. This decision was based on an interpretation of federal law which stated that railroads were only liable for damages if they failed to use spark arresters or other similar devices designed to prevent fires, and there was no evidence suggesting this had occurred in this instance.

In the dissenting opinion for United States v. Chesapeake & Ohio Railway Co., it was argued that the Interstate Commerce Commission (ICC) had overstepped its authority by ordering a refund of freight charges to shippers who were not parties in the proceeding before them. The dissenters believed that while ICC has broad powers, they do not extend to providing reparations or refunds without proper proceedings and due process. They contended that such an action would be akin to judicial power, which is outside of ICC's purview as an administrative body. Furthermore, they expressed concern about potential abuse of this power and infringement on rights if unchecked discretion was given to administrative bodies like ICC without clear legislative guidance or legal safeguards in place.