In the 1904 case of Birrell v. New York and Harlem Railroad Company, the U.S Supreme Court ruled in favor of the defendant, New York and Harlem Railroad Company. The plaintiff, Mr. Birrell had purchased a ticket for travel on one of their trains but was denied entry due to overcrowding. He subsequently sued for breach of contract and won at trial court level; however, this decision was overturned by an appellate court which found that there was no contractual obligation as claimed by Mr. Birrell since his ticket only guaranteed him transportation when space allowed it. The Supreme Court upheld this ruling stating that while railroads are obligated to provide transportation services to passengers who have bought tickets from them, they are not required to guarantee seating or standing room if such accommodations aren't available due to circumstances beyond their control like overcrowding. This landmark case set a precedent regarding passenger rights in public transport systems across America: While service providers must make reasonable efforts towards accommodating all paying customers within capacity limits; they cannot be held liable for failing under extraordinary conditions unless explicitly stated otherwise in terms.

In the dissenting opinion for Birrell v. New York and Harlem Railroad Company, it was argued that the majority's decision to hold a railroad company liable for damages caused by its employees' negligence while performing their duties was unjustified. The dissenting justices believed that this ruling expanded the scope of employer liability beyond what had been previously established in common law principles. They contended that an employer should only be held responsible if they were directly at fault or had failed to exercise due diligence in hiring competent staff. In this case, there was no evidence suggesting any such failure on part of the railroad company; hence, holding them accountable seemed unreasonable and unfair according to these justices.