In the 1924 case of Crouch, Legal Guardian of Konstovich, Widow v. United States, the U.S Supreme Court dealt with a claim for damages under the Federal Employers' Liability Act (FELA). The plaintiff was seeking compensation on behalf of her deceased husband who had been killed while working as an employee for a railroad company engaged in interstate commerce. The main issue revolved around whether or not negligence could be attributed to his employer leading to his death. In its decision, the court ruled that there was sufficient evidence presented at trial which indicated that unsafe work conditions and practices existed at the time of Mr. Konstovich's fatal accident and these were directly attributable to his employer’s negligence. Therefore, it upheld an award granted by lower courts in favor of Mrs.Konstovich.

In the dissenting opinion for Crouch, Legal Guardian of Konstovich, Widow v. United States (1924), Justice McReynolds argued that the court majority had misinterpreted and incorrectly applied immigration law in their decision to deport Mrs. Konstovich. He contended that her marriage to a U.S citizen should have granted her immunity from deportation under existing laws at the time, regardless of whether she was technically an "alien" due to her Russian birthplace or not. Furthermore, he believed it was unjust and against public policy to separate a mother from her American-born children on such grounds. The justice also criticized what he saw as an overly literal interpretation of statutory language by his colleagues which led them to ignore broader principles of fairness and humanity inherent in our legal system.