In the case of Baltimore & Ohio Railroad Company et al. v. Leach, 1918, the U.S Supreme Court was tasked with determining whether a railroad company could be held liable for injuries sustained by an employee who fell from a train due to inadequate safety measures in place. The plaintiff, Mr. Leach had been working as a brakeman and while attempting to climb onto one of the cars during his shift he slipped on ice and fell off because there were no handholds or footholds provided for him to use when climbing aboard moving trains in icy conditions. The court ruled in favor of Mr. Leach stating that it is indeed the responsibility of employers (in this case, the railway company) to provide safe working conditions for their employees including necessary equipment needed for them to perform their duties safely even under adverse weather conditions such as snow or ice which are common occurrences within certain regions where these companies operate.

In the dissenting opinion for Baltimore & Ohio Railroad Company et al. v. Leach, Justice Holmes disagreed with the majority's decision to hold a railroad company liable for damages caused by sparks from its locomotives igniting nearby property. He argued that this interpretation of liability was too broad and could potentially lead to an excessive number of lawsuits against companies whose operations inadvertently cause harm in ways they couldn't reasonably foresee or prevent. Instead, he suggested that liability should be limited to cases where there is clear negligence or recklessness on part of the defendant, rather than simply holding them responsible for any damage their activities might indirectly cause.