In the 1907 case of Chambers v. Baltimore and Ohio Railroad Company, the U.S Supreme Court ruled in favor of the railroad company. The plaintiff, Mr. Chambers, had sued for damages after a train collision resulted in his injury while he was working as a brakeman for another railway company that used tracks owned by Baltimore and Ohio Railroad Company (B&O). He claimed B&O failed to provide safe conditions on their track which led to his injuries. However, the court found no evidence proving negligence on part of B&O or any violation of statutory duty towards him as an employee of another company using its tracks under contractual rights. Therefore, it held that B&O owed no legal responsibility towards Mr.Chambers' safety beyond not willfully causing harm or damage.

In the dissenting opinion for Chambers v. Baltimore and Ohio Railroad Company, it was argued that the majority's decision to deny recovery of damages by Mr. Chambers from the railroad company was incorrect. The dissenting justices believed that there were sufficient grounds to hold the defendant liable for negligence in this case, as they had failed to provide a safe workplace environment which resulted in injury to Mr. Chambers while he was performing his duties as an employee of another contractor on their premises. They contended that even though Mr. Chambers wasn't directly employed by them, they still owed him a duty of care because he worked on their property under conditions controlled by them and thus should be held responsible for any harm caused due to unsafe working conditions.