Leroy Fibre Co. v. Chicago, M. & St. P. Ry. 232 U.S. 340, 34 S.Ct. 415, 58 L.Ed. 631 (1914) Chicago Railroad had a track that went past Leroy's factory. There were bales of flax lying around about 75' from the tracks. A train went past, some sparks flew, and the flax caught fire and burned. Leroy sued for negligence. Chicago argued that Leroy was contributorily negligent because they had left combustible flax lying around next to a railroad. The Trial Court found for Chicago. Leroy appealed. The Trial Court found that Leroy was contributorily negligent. The US Supreme Court reversed. The US Supreme Court found that as a matter of law, a plaintiff cannot be guilty of contributory negligence for using his land in a lawful manner.