In the 1935 case of Chicago Great Western Railroad Co. v. Rambo, Administratrix, the U.S. Supreme Court was tasked with determining whether a railroad company could be held liable for injuries sustained by an employee who fell from a moving train due to his own negligence or carelessness. The plaintiff argued that under the Federal Employers' Liability Act (FELA), employers are responsible for providing safe work environments and can therefore be held accountable even if an employee's actions contribute to their injury. The court ruled in favor of the defendant, Chicago Great Western Railroad Company, stating that while FELA does impose liability on employers for injuries resulting from unsafe conditions at work, it does not hold them accountable when employees knowingly expose themselves to danger without any fault on part of employer. In this particular case, there was no evidence suggesting that the railroad company had failed in its duty to provide a safe workplace; rather it appeared as though Mr.Rambo’s fall resulted solely from his own careless behavior.

The dissenting opinion in the case of Chicago Great Western Railroad Co. v. Rambo, Administratrix argued that the majority's decision to hold the railroad company liable for negligence was incorrect. The dissent emphasized that there were no clear indications or evidence proving beyond a reasonable doubt that the railroad company had been negligent in its duties and responsibilities, leading to an accident causing death. It was pointed out that it is not enough to merely suggest negligence; concrete proof must be provided which clearly shows how such negligence directly resulted in harm or injury. In this case, according to the dissenting justices, such proof was lacking and thus they believed it inappropriate for liability to be placed on the railroad company based solely on speculation and conjecture rather than solid evidence of wrongdoing.