In the case of Boyd v. Grand Trunk Western Railroad Company, 1949, the U.S Supreme Court was tasked with determining whether a railroad company could be held liable for injuries sustained by an employee due to negligence on part of another employee. The plaintiff, Boyd, was injured while working as a brakeman when he fell from a ladder that had been negligently placed by another worker. He sued his employer under the Federal Employers' Liability Act (FELA), which allows employees to sue their employers for injuries caused by co-worker negligence if they can prove that their employer failed in its duty to provide safe working conditions. The court ruled in favor of Boyd and upheld FELA's provision allowing lawsuits against employers based on co-worker negligence. It stated that it is indeed within an employer’s responsibility to ensure safety at work and any failure leading to injury makes them liable under FELA regardless of who exactly committed the negligent act causing harm.

In the dissenting opinion for Boyd v. Grand Trunk Western Railroad Company, it was argued that the majority's decision to uphold a jury verdict in favor of an injured railroad worker was incorrect. The dissent contended that there were significant issues with how evidence had been presented and interpreted during trial, which should have led to a different outcome. Specifically, they believed that certain pieces of evidence were improperly admitted while others were wrongly excluded by the trial judge. They also took issue with instructions given to the jury regarding negligence and causation, arguing these instructions unfairly prejudiced jurors against the defendant company. Ultimately, they felt this combination of errors resulted in an unjust ruling for Boyd and called for a new trial where these mistakes could be rectified.