The U.S. Supreme Court case Chicago Great Western Railroad Company v. Schendel, Administrator of the Estate of Ring, Deceased (1924) revolved around a dispute over liability for an accident that resulted in death on the railroad's property. The deceased was employed by a third-party contractor and not directly by the railroad company when he was killed while working on their premises due to negligence from another employee who also worked for this third party contractor. The court had to decide whether or not the Federal Employers' Liability Act applied in this situation since it generally holds railroads liable for injuries sustained by employees during work-related activities but does not clearly define what constitutes as an "employee". Ultimately, they ruled against applying FELA protections because they concluded that there wasn't enough evidence showing that both parties were acting under direct control and supervision of the railway at time of incident; hence, neither could be considered its employees within meaning of act.

In the dissenting opinion for Chicago Great Western Railroad Company v. Schendel, Justice Holmes argued that the majority's decision was inconsistent with previous rulings and failed to consider important aspects of interstate commerce law. He contended that a railroad company should not be held liable for an accident occurring in one state under another state’s laws if it did not have substantial operations or presence in the latter jurisdiction. In this case, he believed Minnesota had no right to impose its regulations on an incident happening in Iowa where the defendant railway company primarily operated. Furthermore, he criticized the majority's interpretation of federal law as overly broad and warned against setting a precedent that could disrupt interstate business activities by subjecting them to conflicting local regulations from different states.