In the case of Baltimore & Ohio Railroad Company v. Groeger, Administratrix of Groege (1924), the U.S Supreme Court was asked to determine whether a state court had jurisdiction over an out-of-state corporation in a wrongful death suit. The plaintiff, Mrs. Groeger, filed suit against the railroad company in New Jersey after her husband died while working for them in Pennsylvania. The defendant argued that since they were incorporated and based outside of New Jersey, only federal courts could hear this case under diversity jurisdiction rules. The Supreme Court disagreed with this argument and affirmed that state courts do have jurisdiction over such cases if there is sufficient contact between the corporation and the state where it operates or conducts business activities even though its principal place of business or incorporation is elsewhere. In this particular instance, because Baltimore & Ohio Railroad Company operated trains through New Jersey regularly as part of their interstate commerce operations which constituted "doing business" within that State's borders; therefore it was subject to local laws including being sued in its courts.

The dissenting opinion in the case of Baltimore & Ohio Railroad Company v. Groeger argued that the majority's decision to hold the railroad company liable for negligence was incorrect. The dissent contended that there was insufficient evidence to prove negligence on part of the railroad company and therefore, it should not be held responsible for Mr. Groeger's death. They believed that Mr. Groeger had failed to exercise due caution while crossing an unguarded railway track at night, which led to his unfortunate demise by a moving train - an accident he could have avoided if he had been more careful or attentive towards his surroundings.