The Baltimore & Ohio Southwestern Railroad Company v. Carroll, 1929 case revolved around the death of a railroad worker who was killed while on duty in Illinois. The widow and administratrix of his estate, Mrs. Carroll, filed a lawsuit against the company in Missouri where it operated but was not incorporated or had its principal place of business. The issue at hand was whether Missouri courts could exercise jurisdiction over an out-of-state corporation under federal law (Federal Employers' Liability Act). The Supreme Court ruled that state courts have concurrent jurisdiction with federal courts to hear cases arising under this act even if the defendant is an out-of-state corporation operating within their borders. Therefore, Mrs. Carroll's suit could proceed in Missouri despite the fact that neither she nor her deceased husband were residents there and that the accident did not occur there.

In the dissenting opinion for Baltimore & Ohio Southwestern Railroad Company v. Carroll, it was argued that the majority's decision to hold a railroad company liable for injuries sustained by an employee while off duty and not on company property was unjustified. The dissenting justices believed that this ruling expanded employer liability beyond reasonable limits and could have far-reaching implications for businesses across all industries. They contended that employees should be responsible for their own safety during non-working hours and when they are away from their workplace, unless there is clear evidence of negligence or misconduct by the employer. In this case, they did not believe such evidence existed.