The United States Supreme Court case, UNITED STATES et al. v. CHESAPEAKE & OHIO RAILWAY CO. et al., 1975, revolved around the issue of whether or not a railroad company could be held liable for damages caused by sparks from its locomotives under the Federal Employers' Liability Act (FELA). The Chesapeake and Ohio Railway Company was sued by two employees who claimed that they had contracted pneumoconiosis as a result of exposure to harmful dust particles emitted from diesel engines operated by the railway company. The court ruled in favor of the railway company stating that FELA did not cover such claims because it only applied to physical injuries sustained due to negligence on part of employers and did not extend coverage for occupational diseases like pneumoconiosis which were considered an inherent risk associated with certain types of employment.

In the dissenting opinion for United States et al. v. Chesapeake & Ohio Railway Co. et al., Justice Brennan, joined by Justices Stewart and Marshall, argued that the majority's decision was inconsistent with Congress' intent in passing the Interstate Commerce Act (ICA). They believed that Congress intended to give shippers a remedy against unreasonable practices of carriers under Section 1(5) of ICA and disagreed with the majority’s interpretation which limited this right only to situations where there is an absence of effective competition among carriers. The dissenting justices contended that such limitation would leave many shippers without any recourse against unfair carrier practices even when they are subjected to unjust or unreasonable rates or services due to lack of competitive alternatives available in their region.