In the 1947 case Anderson v. Atchison, Topeka & Santa Fe Railway Co., the U.S. Supreme Court ruled in favor of the railway company, reversing a previous decision by the Kansas Supreme Court. The plaintiff, Mrs. Anderson, was suing on behalf of her husband who had been killed while working for the railroad company due to an alleged violation of safety regulations under Federal Employers' Liability Act (FELA). However, it was found that Mr. Anderson's death resulted from his own negligence rather than any breach of duty by his employer as he failed to use available safety equipment properly and did not follow established procedures for safe operation during his work shift when he fell off a moving train car onto tracks below where another train ran over him causing fatal injuries.

In the dissenting opinion for Anderson v. Atchison, Topeka & Santa Fe Railway Co., Justice Frankfurter disagreed with the majority's interpretation of the Federal Employers' Liability Act (FELA). He argued that FELA was not intended to change common law rules regarding proximate cause and liability in negligence cases. Instead, it aimed to ensure railroad workers could recover damages when injured due to their employer's negligence while working interstate commerce. The justice believed that under traditional principles of tort law, a defendant should only be held liable if his negligent act is a substantial factor in bringing about harm. In this case, he did not see evidence proving that railway company’s failure caused Anderson’s death directly or indirectly; hence he would have reversed the judgment.