In the 1931 case of Adams et al. v. Mills, Director General, et al., the United States Supreme Court ruled on a dispute involving railroad workers and their employer regarding compensation for time spent traveling to and from work sites. The plaintiffs were employees of a railway company who claimed that they should be paid for travel time between their homes and distant worksites where they performed maintenance tasks on tracks owned by the company. They argued that this travel was part of their employment duties because it was necessary in order to perform their jobs effectively. The court disagreed with the plaintiffs' argument, ruling that under federal law governing railroad labor relations at the time (the Federal Employers Liability Act), such commuting did not constitute "work" for which an employee could claim compensation from an employer. The court held that while these trips may have been inconvenient or burdensome for employees, they were not considered part of regular working hours under existing laws regulating wages and hours in rail industry employment relationships.

In the dissenting opinion for Adams et al. v. Mills, Director General, et al., Justice Stone argued that the majority's decision to deny compensation to railroad workers who were injured while traveling to work was inconsistent with previous rulings and federal law. He pointed out that under the Federal Employers' Liability Act (FELA), employees are entitled to damages for injuries sustained during their employment, regardless of whether they occur on or off duty. In this case, he believed that since travel was a necessary part of their job as itinerant workers and because their employer had provided them with transportation as part of their contract agreement, any injuries incurred should be considered within the scope of employment under FELA. Therefore, he disagreed with the majority's narrow interpretation which excluded such incidents from coverage by arguing it contradicted Congress’s intent when enacting FELA – ensuring broad protection for railway employees against workplace hazards.