In the 1916 case of Erie Railroad Company v. Winfield, the United States Supreme Court ruled in favor of the railroad company, reversing a decision by New York's highest court. The plaintiff, Mrs. Winfield had sued for damages after her husband was killed while working on an Erie train that derailed due to alleged negligence by the company. She won at trial and on appeal in state courts based on a New York law allowing recovery if death resulted from violation of any statute enacted for safety purposes - even if there was no proof of negligence or intent to harm. However, when appealed to the U.S Supreme Court it held that this application violated federal Employers' Liability Act (FELA), which required proof of negligence leading directly to injury or death before compensation could be awarded under its provisions. The court reasoned that FELA aimed at uniformity across states regarding liability rules applicable in such cases and thus pre-empted conflicting state laws like those applied here.

The dissenting opinion in the case of Erie Railroad Company v. Winfield argued that the plaintiff, who was injured while working for the railroad company, should be allowed to sue under both state and federal laws. The majority ruling held that only federal law applied because railroads are engaged in interstate commerce. However, the dissent contended this interpretation was too narrow and failed to consider important nuances of labor law and workers' rights. They believed that states have a legitimate interest in protecting their citizens from workplace injuries and thus should be able to enforce their own safety regulations alongside federal ones. Furthermore, they pointed out inconsistencies with previous court decisions which had permitted dual enforcement of state and federal laws in other contexts involving interstate commerce.