In the case Boston and Maine Railroad v. Gokey (1907), the U.S Supreme Court ruled in favor of Boston and Maine Railroad, reversing a decision by the New Hampshire Supreme Court. The dispute arose when Mr. Gokey was injured while working for the railroad company due to an alleged negligence on part of his co-worker who was operating a switch engine at that time. Initially, Mr.Gokey won compensation from lower courts based on state law which held employers liable for injuries caused by fellow employees' negligence during work hours if they were acting within their scope of employment. However, upon appeal to the U.S Supreme Court, it was determined that this interpretation contradicted federal laws governing interstate commerce because railroads engaged in such commerce could not be held responsible under state laws for accidents resulting from employee negligence unless there is proof of fault or neglect on part of employer itself or its officers/agents representing them directly rather than ordinary employees like switchmen etc., as per Employers Liability Act passed earlier by Congress.

In the dissenting opinion for Boston and Maine Railroad v. Gokey, Justice Harlan disagreed with the majority's ruling that a railroad company could not be held liable for damages caused by sparks from its locomotives if it had taken all reasonable precautions to prevent such occurrences. He argued that railroads should be considered dangerous agencies due to their inherent risk of causing fires, regardless of whether they were operated negligently or not. Therefore, he believed that railroads should always bear responsibility for any damage caused by sparks emitted from their engines. In his view, this would provide an incentive for them to take even greater care in preventing such incidents and ensure fair compensation for those affected by these risks associated with railway operations.