In the case of Affholder v. New York, Chicago & St. Louis Railroad Co., 1949, the U.S Supreme Court dealt with a dispute over an employment contract between a railroad company and its employee who was injured on duty. The plaintiff, Mr. Affholder had signed an agreement with his employer that he would not sue for damages if he were injured while working due to negligence by fellow employees or himself but only claim compensation under the Federal Employers' Liability Act (FELA). After suffering injuries in two separate incidents at work, Affholder sued for damages beyond what FELA provided claiming that such agreements are void as against public policy and violate federal law which allows workers to sue their employers for negligence causing injury. The court ruled in favor of the defendant railroad company stating that there is no federal law prohibiting such contracts where workers agree not to seek additional damages from their employers beyond those provided by FELA when they suffer injuries caused by co-workers or themselves during work hours.

In the dissenting opinion for Affolder v. New York, Chicago & St. Louis Railroad Co., it was argued that the majority's decision to hold a railroad company liable for injuries sustained by an employee while off duty and not on company property was unjustified. The dissenting justices believed that this ruling expanded the scope of liability under the Federal Employers' Liability Act (FELA) beyond its intended limits, which they interpreted as applying only to injuries incurred during employment or in work-related situations. They contended that extending FELA protection to incidents occurring outside of these parameters would lead to excessive litigation and financial burdens for employers without necessarily improving safety conditions for employees. Furthermore, they expressed concern about setting a precedent where companies could be held responsible for their workers' actions even when those actions were unrelated to their jobs or took place in locations over which employers had no control.