In the 1905 case of Armour Packing Company v. Lacy, the U.S. Supreme Court ruled in favor of Armour Packing Company, reversing a decision by the Kansas Supreme Court that had awarded damages to an employee injured while working at one of its plants. The court found that under federal law, employers were not liable for injuries sustained by their employees during work unless negligence could be proven on part of the employer or fellow employees. In this particular case, it was determined that there was no evidence showing any negligence from either party and therefore, according to federal law as interpreted by Justice Oliver Wendell Holmes Jr., who delivered the opinion for a unanimous court; Mr.Lacy's injury fell within his own risk assumed as part of his employment contract with Armour Packing Co.

In the dissenting opinion for Armour Packing Company v. Lacy, the justice disagreed with the majority's interpretation of what constitutes a "public nuisance." The dissent argued that just because an activity is lawful and beneficial to society does not mean it cannot also be a public nuisance if it causes harm or inconvenience to others. In this case, they believed that despite being legal and economically important, Armour Packing Company’s operation could still constitute as a public nuisance due to its harmful effects on nearby residents' health and comfort. They contended that any business causing such significant damage should be held accountable regardless of their economic contributions or legality of operations. This view emphasized more on individual rights over corporate interests.