In the case of Chicago, Rock Island & Pacific Railway Company v. Cramer in 1913, the U.S Supreme Court was tasked with determining 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, Cramer, had been injured while repairing a train car that had previously been used in interstate commerce but was not actively being used as such when he got hurt. The court ruled against Cramer and found that under the Federal Employers' Liability Act (FELA), employees were only protected if they were engaged in interstate commerce at their time of injury. This ruling clarified FELA's scope and established precedent for future cases involving worker injuries on railroads.

In the dissenting opinion for Chicago, Rock Island & Pacific Railway Company v. Cramer, it was argued that the court majority erred in its interpretation of liability under federal law. The dissenter believed that the railway company should not be held responsible for injuries sustained by an employee while performing his duties if he had knowledge of potential dangers and chose to proceed anyway. This viewpoint emphasized personal responsibility over employer negligence, arguing that employees have a duty to protect their own safety when aware of risks involved in their work tasks. The dissent also criticized the majority's reliance on state laws to determine liability rather than strictly adhering to federal statutes governing railroad worker protections. It was suggested this approach could lead to inconsistent rulings across different jurisdictions and undermine uniformity in national labor standards.