In the 1910 case of Chicago, Burlington and Quincy Railway Company v. Willard, the U.S. Supreme Court was tasked with deciding whether a railway company could be held liable for injuries sustained by an employee who was not directly involved in interstate commerce at the time of his injury. The plaintiff, Mr. Willard, had been injured while working on a train car that was temporarily out of service for repairs but would later return to use in interstate commerce once fixed. The court ruled in favor of Mr. Willard stating that although he wasn't engaged in interstate commerce at the exact moment he got hurt, his work still contributed to it indirectly as it facilitated future operations related to such trade activities; hence making him eligible for compensation under federal law (the Federal Employers' Liability Act). This ruling expanded protections offered by this act beyond workers directly involved with interstate transportation tasks.

In the dissenting opinion for the case of Chicago, Burlington and Quincy Railway Company v. Willard, it was argued that the majority's decision to hold a railway company liable for injuries sustained by an employee while on duty is unjustified. The dissenting justices believed that there were no sufficient grounds to establish negligence on part of the employer as required under common law principles. They contended that accidents can occur even in environments where utmost care has been taken to ensure safety and such incidents should not automatically be attributed to negligence or failure of duty by employers. The dissenters also expressed concern over how this ruling could set a dangerous precedent leading towards unwarranted litigation against corporations and businesses whenever workplace accidents happen irrespective of whether they had exercised due diligence or not.