In the case of Chicago, Rock Island and Pacific Railway Company v. Sturm in 1898, the U.S Supreme Court ruled on a dispute involving freight charges for transporting goods across state lines. The railway company had charged Mr. Sturm an amount that he believed was excessive under Nebraska law. However, the railway company argued that since it was engaged in interstate commerce at the time of transportation, it should be governed by federal laws instead of state regulations. The court sided with Mr. Sturm and held that even though railways were involved in interstate commerce, they could still be regulated by individual states when operating within their borders if there is no conflict with federal law or regulation from Congress regarding such matter. This decision affirmed states' rights to regulate businesses within their jurisdiction while also recognizing the supremacy of federal law over interstate commerce when applicable.

In the dissenting opinion for Chicago, Rock Island and Pacific Railway Company v. Sturm, it was argued that the majority's decision to hold a railway company liable for damages caused by an employee who acted outside of his scope of employment was incorrect. The dissenting justices believed this ruling expanded the employer’s liability beyond established legal principles. They contended that an employer should only be held responsible for actions committed by employees during their duties or within their authority given by the employer. In this case, they pointed out that the employee had clearly overstepped his boundaries and acted independently when he assaulted Mr.Sturm without any provocation or connection to his job as a ticket agent at all. Therefore, according to them, holding employers accountable in such situations would set a dangerous precedent where businesses could be unfairly burdened with liabilities arising from unpredictable and uncontrollable actions of their employees.