In the 1931 case of Atlantic Coast Line Railroad Co. v. Temple, Administratrix, the U.S Supreme Court ruled in favor of the railroad company. The case arose from a fatal accident involving an employee of Atlantic Coast Line Railroad who was struck by a train while working on tracks owned by another railway company (Seaboard Airline Railway). The widow and administratrix of his estate, Mrs. Temple, sued for damages under the Federal Employers' Liability Act (FELA), claiming that her husband's death resulted from negligence on part of his employer. The key issue before the court was whether FELA applied when an employee is injured or killed while working on tracks not owned by their employer but used through trackage rights agreements between railroads. In its decision, the Supreme Court held that such situations did fall within FELA’s purview as long as it could be proven that there was negligence leading to injury or death. However, in this particular instance, they found no evidence proving any negligent act committed by Atlantic Coast Line Railroad which might have contributed to Mr.Temple's unfortunate demise; hence they reversed previous judgments awarding damages to Mrs.Temple.

The dissenting opinion in the case of Atlantic Coast Line Railroad Co. v. Temple, 1931, argued that the court majority had wrongly applied a federal law to a state matter and overstepped its jurisdictional boundaries. The dissenters believed that the issue at hand was one of negligence under Georgia's state laws rather than an interpretation or application of federal safety regulations for railroads. They contended that it should have been left to local courts to decide whether there was sufficient evidence for a jury trial on negligence claims against the railroad company following an accident which resulted in death. The dissenting justices felt strongly about maintaining respect for states' rights and autonomy within their legal systems, arguing this principle is fundamental to America’s constitutional structure.