In the 1946 case of Ellis v. Union Pacific Railroad Co., the United States Supreme Court ruled on a dispute involving an employee's right to compensation for injuries sustained while working. The plaintiff, Mr. Ellis, was injured during his employment with Union Pacific Railroad and sought damages under the Federal Employers' Liability Act (FELA). However, he had previously signed a contract agreeing to arbitration in such cases as part of his union membership agreement. The court held that this agreement did not bar him from seeking damages through FELA because federal law superseded any contractual obligations between employer and employee or between union members themselves regarding personal injury claims arising out of negligence at work place. Therefore, despite having agreed to settle disputes via arbitration within his labor organization, Mr.Ellis could still pursue legal action against his employer under federal law.

In the dissenting opinion for Ellis v. Union Pacific Railroad Co., Justice Frank Murphy argued that the majority's decision was a departure from established principles of law regarding negligence and liability. He contended that it is not necessary to prove actual knowledge of danger in order to establish negligence, but rather, what should be considered is whether there was reasonable foreseeability of harm. In this case, he believed that the railroad company had sufficient reason to anticipate possible injury due to its failure to maintain safe conditions on its property. Therefore, according to him, they were negligent and liable for damages caused by their lack of proper maintenance and inspection procedures. Furthermore, he disagreed with the majority's interpretation of "occupier" under Utah law as excluding railroads; instead asserting that railroads should indeed be held accountable as occupiers when they fail in their duty towards those who are rightfully on their premises.