In the case of Brown v. Western Railway of Alabama in 1949, the U.S Supreme Court ruled on a matter concerning negligence and liability for damages during interstate commerce. The plaintiff, Brown, was an employee of the railway company who suffered injuries while working due to alleged negligence by his employer. He sued under the Federal Employers' Liability Act (FELA), which allows railroad workers to claim compensation for work-related injuries resulting from their employers’ negligence. The main issue before the court was whether FELA applied since part of Brown's duties included intrastate tasks not directly related to interstate commerce - he had been injured while performing such a task. The lower courts held that because his injury occurred during an intrastate activity, FELA did not apply. However, upon appeal to the Supreme Court it was determined that if an employee’s overall duties were primarily in furtherance of interstate commerce – as they were with Mr. Brown – then any injury sustained during employment could be covered by FELA regardless if it happened during an intrastate task or not. Thus reversing previous rulings and finding in favor of Mr.Brown; this decision expanded protections offered by federal law for railroad employees involved in both intra- and inter-state activities.

In the dissenting opinion for Brown v. Western Railway of Alabama, Justice Robert H. Jackson disagreed with the majority's decision to hold a railway company liable for injuries sustained by an employee while on duty. He argued that this interpretation expanded the Federal Employers' Liability Act (FELA) beyond its intended scope and could lead to unjust outcomes in future cases. According to Justice Jackson, FELA was designed specifically to protect railroad workers from negligence by their employers, not accidents caused by third parties or unforeseeable events outside of their control. In his view, holding companies responsible for such incidents would unfairly burden them with costs they cannot predict or prevent and may discourage businesses from operating in high-risk areas altogether.