In the case of Carter v. Atlanta & St. Andrews Bay Railway Co., 1949, the U.S Supreme Court ruled in favor of the railway company, dismissing a claim made by an employee under the Federal Employers' Liability Act (FELA). The plaintiff, Mr. Carter, was injured while working for the defendant and sought compensation for his injuries based on negligence on part of his employer as per FELA provisions. However, it was found that at no point during his employment did he engage in any activities related to interstate commerce - a prerequisite for FELA applicability according to previous court rulings (Philadelphia B & W.R.Co vs Smith). Therefore, despite being employed by an interstate carrier company and suffering from work-related injuries due to alleged negligence by said employer; since Mr.Carter's duties were not directly involved with or affecting interstate commerce at any time during his tenure when he got injured; hence he could not seek relief under FELA.

In the dissenting opinion for Carter v. Atlanta & St. Andrews Bay Railway Co., Justice Robert H. Jackson argued that the majority's decision to allow a state court to exercise jurisdiction over an out-of-state defendant, based solely on service of process upon an agent who was not authorized to accept it, violated due process rights under the Fourteenth Amendment. He contended that this ruling expanded state power at the expense of individual rights and federal authority, undermining constitutional protections against arbitrary government action. Furthermore, he criticized the majority for failing to provide clear guidelines about when such jurisdiction would be permissible in future cases, creating uncertainty and potential injustice for defendants facing similar circumstances.