In the 1933 case of Fairport, Painesville & Eastern Railroad Co. v. Meredith, the U.S Supreme Court ruled in favor of the railroad company and reversed a decision made by an Ohio state court that had awarded damages to Meredith for injuries sustained during his employment with the railroad company. The main issue was whether or not federal law preempted state law in this context - specifically regarding employer liability for worker injuries under Federal Employers' Liability Act (FELA). The Supreme Court held that FELA did indeed supersede state laws on this matter and thus, any claims brought forward should be governed by its provisions instead of those provided by individual states. Therefore, since Meredith's claim didn't meet FELA requirements as it failed to prove negligence on part of his employer leading to injury; he wasn't entitled to compensation under federal law.

In the dissenting opinion for Fairport, Painesville & Eastern Railroad Co. v. Meredith, Justice Cardozo expressed concern over the majority's decision to allow a railroad company to avoid liability for an accident caused by its negligence simply because it had contracted with another party who agreed to assume responsibility for such accidents. He argued that this ruling undermined public policy and common law principles which hold parties accountable for their own negligent actions. Furthermore, he contended that allowing companies to contractually shift blame in this manner could lead to abuses where powerful entities might coerce weaker ones into accepting unfair terms of agreement under duress or out of economic necessity.