The United States Supreme Court case, UNITED STATES et al. v. CHICAGO, MILWAUKEE, ST. PAUL & PACIFIC R. CO. et al., 1934 revolved around the issue of whether or not a railroad company could be held liable for damages caused by forest fires that were allegedly started due to negligence on their part in maintaining and operating their locomotives and equipment properly. The government argued that the railway company's failure to take necessary precautions resulted in significant damage to public lands through these fires which they should compensate for under federal statutes related to fire prevention on such lands. However, the court ruled in favor of the Chicago, Milwaukee, St Paul & Pacific Railroad Company stating that while there was evidence suggesting negligence on their part leading up to these incidents; it wasn't sufficient enough under existing law at that time (which required proof beyond reasonable doubt) for them being held legally responsible or liable financially towards any resulting damages from said wildfires.

In the dissenting opinion for United States v. Chicago, Milwaukee, St. Paul & Pacific R.R. Co., Justice Stone argued that the Interstate Commerce Commission (ICC) should have been allowed to exercise its discretion in determining whether a railroad company could abandon unprofitable lines without undue harm to public interest. He believed that Congress had granted this power to the ICC and it was not within the Court's jurisdiction to overrule such decisions unless they were arbitrary or capricious. The majority decision, he felt, undermined this principle by substituting their judgment for that of an expert administrative body specifically tasked with making these determinations based on comprehensive investigations and hearings.