In the 1973 case Dillard et al. v. Industrial Commission of Virginia et al., the U.S Supreme Court addressed a dispute over workers' compensation benefits for an employee who died from a heart attack while at work. The court had to determine whether his death was caused by his employment or if it could be attributed to natural causes unrelated to his job. The deceased's family argued that he experienced unusual stress and strain during his shift, which contributed significantly to triggering the fatal heart attack, thus making them eligible for workers’ compensation benefits under Virginia law. The court ruled in favor of the employer, stating that there wasn't sufficient evidence proving that work-related stress directly caused or hastened the worker’s death due to cardiac arrest. It emphasized that mere conjecture or supposition isn’t enough; there must be some reasonable connection between injury and employment established through competent medical testimony.

In the dissenting opinion for Dillard et al. v. Industrial Commission of Virginia et al., the justice argued that the majority's decision was inconsistent with previous rulings and violated principles of federalism by allowing a state agency to regulate interstate commerce, which is constitutionally reserved for Congress. The justice contended that this case involved an interstate transaction because it concerned workers who were hired in North Carolina but injured in Virginia while working on a federally funded highway project. Therefore, he believed that only federal law should apply, not Virginia’s Workers' Compensation Act as decided by the majority. He also expressed concern about potential negative implications for future cases involving similar circumstances if states are allowed to impose their own regulations on such transactions.