In the case of Atlantic Coast Line Railroad Company v. Mims, 1916, the U.S Supreme Court ruled in favor of Mrs. Mims, who was suing for damages following her husband's death while working on a railroad construction project managed by Atlantic Coast Line Railroad Company. The court held that under South Carolina law and federal Employers' Liability Act (FELA), an employer is liable for injuries or deaths caused by negligence even if they occurred outside regular work hours or off-site as long as they were related to employment duties. In this instance, Mr. Mims had been killed during his commute from his workplace back home which was provided by the company itself; hence it fell within the scope of employment-related activities making Atlantic Coast Line responsible for compensation.

The dissenting opinion in the Atlantic Coast Line Railroad Company v. Mims case argued that the majority's decision to allow state courts to exercise jurisdiction over cases involving federal employers' liability was a misinterpretation of Congress' intent when it passed the Employers’ Liability Act. The dissent believed that Congress intended for these types of disputes to be handled exclusively by federal courts, as they involve questions of federal law and policy. They also expressed concern about potential inconsistencies in rulings if state courts were allowed to handle such cases, given their differing interpretations and applications of laws. Furthermore, they pointed out that allowing state court jurisdiction could potentially undermine uniformity in legal standards across states - an important aspect considering interstate commerce is involved here.