The case of Chicago, Milwaukee & St. Paul Railway Company v. Coogan in 1925 revolved around the issue of whether a state law could impose liability on an employer for injuries sustained by its employees while working outside the state's jurisdiction. The plaintiff, Mrs. Coogan, was seeking compensation from her deceased husband's employer under Minnesota’s Workmen Compensation Act after he died from injuries obtained during his employment with the railway company in North Dakota - a location beyond Minnesota’s jurisdictional boundaries. The U.S Supreme Court ruled that although Mr. Coogan had been hired in Minnesota and his contract stipulated that it was governed by Minnesota laws, these factors did not give the state authority to enforce its laws outside its territorial limits or hold employers liable for accidents occurring elsewhere. This decision established important precedent regarding states' rights and their limitations concerning extraterritorial application of their own labor protection statutes.

In the dissenting opinion for Chicago, Milwaukee & St. Paul Railway Company v. Coogan, it was argued that the majority's decision to award damages based on future earnings potential of a minor child who died in an accident was speculative and without precedent. The dissenting justices contended that there were too many variables involved in predicting a child's future earning capacity such as health, education, personal choices and economic conditions which made any estimation unreliable and potentially unfair to the defendant company. They also pointed out that this approach could lead to wildly varying awards depending on subjective assessments of a child’s potential rather than objective facts related to actual loss suffered by parents due to their child’s death.