In the 1931 case of Atchison, Topeka & Santa Fe Ry. Co. v. Saxon, Ancillary Administrator, the U.S Supreme Court ruled in favor of Atchison, Topeka & Santa Fe Railway Company (ATSF). The dispute arose when a train operated by ATSF collided with an automobile at a crossing resulting in two fatalities and one injury. The victims' families filed lawsuits against ATSF claiming negligence on their part for not providing adequate warning signals at the crossing point where the accident occurred. However, after reviewing evidence presented during trial proceedings which included testimonies from eyewitnesses and examination of physical conditions surrounding the incident site such as visibility factors etc., it was determined that there were no substantial grounds to establish negligence on behalf of ATSF since they had complied with all statutory requirements regarding safety measures at railway crossings including installation and maintenance of appropriate warning devices like crossbucks or signs indicating presence/absence thereof.

In the dissenting opinion for Atchison, Topeka & Santa Fe Ry. Co. v. Saxon, Justice Stone argued that the majority's decision to allow a state court to exercise jurisdiction over an out-of-state corporation was inconsistent with due process principles and previous Supreme Court rulings on this issue. He contended that merely conducting business in a state does not establish sufficient contacts for a court in that state to have jurisdiction over all matters involving the company, particularly when those matters are unrelated to its activities within the state itself. In his view, allowing such broad assertions of jurisdiction would unfairly burden interstate commerce by subjecting companies operating across multiple states to potentially conflicting legal obligations and standards.