In the 1917 case of Boldt v. Pennsylvania Railroad Company, the U.S. Supreme Court was asked to determine whether a railroad company could be held liable for injuries sustained by an employee while on duty, even if those injuries were not directly caused by negligence on part of the employer. The plaintiff, Mrs. Boldt, acting as administratrix of her late husband's estate, argued that her husband had died due to exhaustion and overwork imposed by his job at the Pennsylvania Railroad Company. However, there was no evidence presented showing any specific act or omission constituting negligence on part of the defendant company which led to Mr.Boldt’s death. The court ruled in favor of Pennsylvania Railroad Company stating that under Federal Employers' Liability Act (FELA), it is necessary for liability that injury resulted from some fault attributable to employer; mere fact that injury occurred while employee was engaged in interstate commerce does not impose liability upon employer without proof establishing such fault.

In the dissenting opinion for Boldt v. Pennsylvania Railroad Company, it was argued that the majority's decision to uphold a lower court ruling in favor of the railroad company was incorrect. The dissenting justices believed that there were significant issues with how evidence had been presented and interpreted during trial proceedings. They contended that certain pieces of evidence should not have been admitted due to their speculative nature, while others should have received more serious consideration by jurors. Furthermore, they disagreed with the majority's interpretation of liability laws as applied to this case; specifically, they felt that these laws did not absolve companies from responsibility when employee negligence contributed to an accident or injury on company property. Overall, they believed that justice would be better served if a new trial were granted where these evidentiary and legal errors could be corrected.