In the Chesapeake and Ohio Railway Company v. Dixon case of 1900, the U.S Supreme Court ruled in favor of Dixon, who had sued for damages after a train accident caused by alleged negligence on part of the railway company's employees. The court held that under Kentucky law, where the incident occurred, an employer is liable for injuries to third parties resulting from its employee’s negligence while performing their duties within their scope of employment. This principle applied even if there was no evidence proving direct fault or misconduct by the employer itself. Therefore, it was irrelevant whether or not Chesapeake and Ohio Railway Company could have foreseen or prevented its employee's negligent actions leading to Dixon's injury; they were still legally responsible as per vicarious liability rules.

In the dissenting opinion for Chesapeake and Ohio Railway Company v. Dixon, Justice Harlan argued that the majority's decision was inconsistent with previous rulings regarding employer liability in cases of employee injury. He contended that if an employer knowingly exposes their employees to unnecessary risks or fails to provide a safe working environment, they should be held accountable for any resulting injuries. In this case, he believed that the railway company had failed to maintain its equipment properly which led directly to Dixon's injury. Therefore, according to him, it was unjust not only from a legal standpoint but also morally wrong for the court majority ruling absolving them of responsibility towards their employee’s safety and well-being.