The U.S. Supreme Court case Chicago, Rock Island & Pacific Railway Company v. Cole, Administratrix of Roberts in 1919 revolved around a dispute over the liability for an accident that resulted in the death of a railway employee named Roberts. The plaintiff, Cole (the administratrix of Robert's estate), argued that the railway company was responsible due to negligence under the Federal Employers' Liability Act (FELA). However, there were conflicting testimonies regarding whether or not safety rules had been violated by either party at the time of incident. The court ruled in favor of Cole and held that it was up to a jury to decide on matters concerning contributory negligence and assumption of risk under FELA - thus rejecting arguments made by defendant about directed verdicts based on evidence presented during trial proceedings.

In the dissenting opinion for the case of Chicago, Rock Island & Pacific Railway Company v. Cole, it was argued that there was no legal basis to hold a railway company liable for injuries sustained by an employee while performing his duties in another state where he is not ordinarily employed. The dissenting justices contended that under federal law and precedent, liability should be determined based on the laws of the state where employment usually occurs rather than those of a different jurisdiction where an injury incidentally happens. They also expressed concern about potential negative implications this ruling could have on interstate commerce if companies were required to comply with varying workers' compensation laws across states. Thus, they disagreed with majority's decision which held that Kansas law applied even though Roberts’ primary place of work was Oklahoma because his fatal accident occurred in Kansas.