In the case of Burton v. New York Central & Hudson River Railroad Company, 1917, the United States Supreme Court ruled in favor of the defendant railroad company. The plaintiff, Burton, a brakeman for another railway company was injured while attempting to couple cars on a track owned by New York Central & Hudson River Railroad Company (NYC&HR). He claimed that NYC&HR failed to provide him with safe working conditions as required under federal law - specifically citing inadequate lighting which led to his injury. However, the court held that since he was not an employee of NYC&HR and because his employer had full control over his work activities at all times including when he got injured; therefore NYC&HR owed no duty towards him under federal safety laws applicable only between employers and their employees. Thus it could not be held liable for any negligence leading to Burton's injuries.

In the dissenting opinion for Burton v. New York Central & Hudson River Railroad Company, Justice Holmes argued that the railroad company should not be held liable for damages caused by a fire that started on its property and spread to neighboring properties. He contended that while it was true the company had been negligent in allowing sparks from one of its engines to start a fire on its land, this negligence did not extend beyond their own property lines. Therefore, according to Holmes' interpretation of tort law principles, since there was no direct trespass onto another's property or personal injury inflicted upon others due to this negligence, there could be no liability imposed upon them for consequential damages suffered by neighbors as a result of such fires spreading beyond their premises. This view contrasts with majority’s ruling which found NY Central responsible based on principle of foreseeability i.e., they should have foreseen potential harm caused by such fires extending beyond their boundaries.