The U.S. Supreme Court case Baugham, Administrator of Baugham v. New York, Philadelphia & Norfolk Railroad Company in 1915 revolved around a dispute over the liability for an accident that occurred on a railroad crossing resulting in death. The deceased was driving a horse-drawn wagon across the tracks when it was hit by an oncoming train. The administrator of his estate sued the railroad company claiming negligence as there were no warning signals or guards at this particular crossing and visibility was poor due to surrounding buildings and structures. However, evidence showed that despite these conditions, if proper care had been taken by looking both ways before attempting to cross - which is considered standard practice - then the approaching train could have been seen from quite some distance away. The court ruled in favor of the defendant (the railroad company), stating that while railroads do have certain responsibilities towards safety measures at crossings, individuals also bear responsibility for their own safety and must exercise reasonable caution when using such crossings.

The dissenting opinion in the case of Baugham v. New York, Philadelphia & Norfolk Railroad Company argued that the majority's decision was incorrect because it failed to properly consider and apply relevant state laws. The dissent believed that Maryland law should have been applied given that the accident occurred there, rather than Virginia law as determined by the majority. According to Maryland law, a person who voluntarily puts himself in a dangerous situation cannot recover damages for any injury suffered as a result; however, this does not mean they are barred from recovery if their actions were not reckless or negligent but merely imprudent or unwise. Therefore, under Maryland law, Baugham could potentially recover damages despite his contributory negligence since he did not act recklessly or with gross negligence when crossing the railroad tracks at night without looking out for oncoming trains.