In the case of West Side Belt Railroad Company v. Pittsburgh Construction Company, 1910, the U.S Supreme Court was tasked with determining whether a railroad company could be held liable for damages caused by sparks from its locomotives setting fire to property adjacent to its tracks. The Pittsburgh Construction Company had sued the West Side Belt Railroad after one such incident resulted in significant damage to their lumber yard. The court ruled that while railroads are not insurers against accidental fires started by sparks from their engines, they can be held responsible if it is proven that they were negligent or failed to use available technology and precautions known at the time to prevent such incidents. In this particular case, however, there was no evidence presented suggesting negligence on part of the railroad company nor any proof showing existence of better spark arresters than those used by them during that period; hence it wasn't found liable for damages.

The dissenting opinion in the case of West Side Belt Railroad Company v. Pittsburgh Construction Company argued that the majority's decision was not consistent with previous rulings and legal principles regarding property rights and easements. The dissent believed that the railroad company had a clear right to use its own land for any lawful purpose, including constructing additional tracks, as long as it did not interfere with the construction company's existing easement rights. They contended that there was no evidence showing such interference or damage caused by these new tracks to warrant an injunction against their construction. Furthermore, they disagreed with the majority’s interpretation of what constituted 'reasonable' use of property under an easement agreement, arguing this should be determined on a case-by-case basis rather than applying blanket restrictions which could unduly limit property owners’ rights.