In the 1918 case of Andrews, Administratrix of Andrews v. Virginian Railway Company, the U.S. Supreme Court ruled in favor of the railway company. The plaintiff was suing on behalf of her deceased husband who had been killed while working for the defendant as a brakeman when he fell from a moving train and died instantly due to injuries sustained from his fall. The plaintiff alleged that her husband's death was caused by negligence on part of his employer - failure to provide safe equipment and violation of federal safety laws regarding railroad employees' work hours. However, there were no witnesses or substantial evidence supporting these claims except for an unexplained accident report stating that Mr.Andrews had fallen off a car ladder which could have resulted from any number reasons including personal carelessness or misstep.The court held that mere conjecture or speculation is not sufficient basis for liability; it must be proven with reasonable certainty through factual evidence that negligence occurred causing injury/death.Therefore,the judgement favored Virginian Railway Company since Mrs.Andrews failed to prove their direct responsibility towards her husband's fatal accident.

In the dissenting opinion for Andrews v. Virginian Railway Company, Justice Holmes argued that the railway company should not be held liable for Mr. Andrew's death because it was not a direct result of their negligence. He contended that while the company may have been negligent in maintaining its equipment, this did not directly cause Mr. Andrews to fall from his car and subsequently get run over by another train on an adjacent track - these were separate incidents with different causes and consequences. According to him, there was no clear causal link between the railway's alleged negligence and Mr. Andrew's unfortunate demise; thus holding them responsible would set a dangerous precedent where companies could be held accountable for any harm suffered by their employees or customers even if they had little or no control over those circumstances.