In the 1903 case of Baltimore & Potomac R. R. Co. v. Landrigan, the U.S Supreme Court ruled in favor of the railroad company after it was sued by an employee who had been injured on duty due to alleged negligence on part of his fellow employees and supervisors. The court held that under federal law, a common carrier is not liable for injuries sustained by its employees while they are engaged in their duties unless such injuries were caused directly by negligence or misconduct from the employer itself or someone acting with its authority, rather than other co-workers at same level as plaintiff's employment status within organization hierarchy structure . This ruling established important precedent regarding liability issues between employers and their workers during workplace accidents incidents.

In the dissenting opinion for Baltimore & Potomac R.R. Co v. Landrigan, it was argued that the majority's decision to hold a railroad company liable for injuries sustained by an employee due to negligence of another employee contradicted established principles of law and precedent cases. The dissenter contended that there should be no liability unless there is proof of negligence on part of those who are in effect representatives or alter egos of the corporation itself such as its officers or those performing duties which are non-delegable. It was also pointed out that if this principle were applied universally, it would result in unjust outcomes where corporations could potentially be held responsible for every wrong committed by any one among thousands employed under them even when they had exercised all reasonable care and diligence in their supervision and control.