In the 1972 case of Dillard v. Industrial Commission of Virginia, the U.S Supreme Court dealt with a dispute over workers' compensation benefits. The petitioner, Mrs. Dillard, sought to claim these benefits following her husband's death from a heart attack which she argued was caused by his work-related stress and exertion as an employee for the City of Richmond Fire Department in Virginia. However, both lower courts denied her claims on grounds that there wasn't sufficient evidence proving Mr.Dillard’s job directly resulted in his fatal heart attack. Mrs.Dillard appealed this decision to the Supreme Court arguing that it violated equal protection under law because firefighters were treated differently than police officers who had similar risks and stresses associated with their jobs but were entitled to presumption that any heart disease or hypertension is occupationally related. The Supreme Court upheld the lower court rulings stating there was no violation since different treatment between two groups does not necessarily imply discrimination if based on rational legislative objectives; here being differences in nature and conditions of employment between firefighters and police officers.

In the dissenting opinion for Dillard v. Industrial Commission of Virginia, it was argued that the majority's decision to deny workers' compensation benefits to Mrs. Dillard failed to consider key aspects of her case and misinterpreted relevant laws. The dissenting justices believed that Mrs. Dillard should be considered a statutory employee under Virginia law because she performed work as part of her landlord's trade or business in exchange for reduced rent, which constituted payment in kind rather than traditional wages. They also disagreed with the majority's interpretation of "casual" employment, arguing that Mrs. Dillard’s regular and ongoing cleaning duties did not fit this definition simply because they were performed on an irregular schedule or without formal terms of employment.