In the case of Crane v. Cedar Rapids & Iowa City Railway Co., 1968, the U.S Supreme Court ruled on a dispute involving federal preemption over state law in matters relating to interstate commerce. The plaintiff, Crane, was injured while working for Cedar Rapids & Iowa City Railway Co and sought compensation under an Iowa statute that allowed employees to sue their employers for injuries caused by co-workers' negligence. However, the railway company argued that this state law was preempted by federal legislation - specifically the Federal Employers' Liability Act (FELA), which did not allow such lawsuits. The court sided with Crane and held that FELA did not supersede or displace state laws allowing workers to sue their employers for injuries caused by fellow employees’ negligence unless those suits were based on conduct regulated by FELA itself. This decision affirmed states' rights in certain areas of worker protection even when there is existing relevant federal legislation.

In the dissenting opinion for Crane v. Cedar Rapids & Iowa City Railway Co., Justice Harlan argued that the majority's decision to allow a plaintiff to recover damages under both state law and federal safety regulations was incorrect. He contended that allowing dual recovery would undermine uniformity in railroad regulation, which is one of the main purposes of federal control over this industry. Furthermore, he expressed concern about potential double liability for railroads as it could lead to excessive penalties beyond what Congress intended when they enacted these safety laws. In his view, if a violation of federal standards can be shown, then any additional recovery under state law should be precluded because it essentially amounts to punishing the same conduct twice.