In the 1930 case Atlantic Coast Line Railroad Co. v. Powe, Administrator, the U.S Supreme Court ruled in favor of Atlantic Coast Line Railroad Company (ACL). The issue at hand was whether or not ACL should be held liable for a fatal accident that occurred on its property due to an alleged failure to provide adequate safety measures. The victim's administrator argued that ACL had violated South Carolina state law by failing to install safety appliances and maintain safe conditions on their premises as required under federal law. However, the court found no evidence proving negligence on part of ACL nor any violation of federal laws regarding railroad safety standards. Therefore, it concluded that there was no basis for liability against ACL under either state or federal law and reversed a lower court decision which had awarded damages to the victim's estate.

The dissenting opinion in the Atlantic Coast Line Railroad Co. v. Powe case argued that the majority's decision was inconsistent with previous rulings and failed to adequately consider relevant state laws. The dissent took issue with the majority's interpretation of a South Carolina statute, which they believed should have been interpreted as allowing for recovery in cases where death is caused by negligence, even if there were no actual damages at the time of death. They also disagreed with how much weight was given to federal law over state law in this matter, arguing that it undermined states' rights and autonomy. Furthermore, they contended that denying recovery on these grounds could lead to unjust results where negligent parties are not held accountable for their actions simply because their victims died instantly rather than suffering measurable harm before dying.