In the 1951 case of First National Bank of Chicago, Executor v. United Air Lines, Inc., the U.S. Supreme Court ruled on a dispute involving an air crash that resulted in death and injury to passengers. The plaintiff was the executor for one of those killed in the accident and sued United Airlines for negligence under Illinois law which allowed recovery without proof of willful misconduct or gross negligence if there was a contract between passenger and carrier (in this case, a plane ticket). However, federal law required such proof when suing airlines involved in interstate commerce. The court had to decide whether state or federal law applied. The Supreme Court held that while states have power over wrongful death actions within their borders, they cannot impose liability standards inconsistent with federal laws governing aviation safety. Therefore, it determined that Federal Aviation Act preempts state common-law claims against airlines regarding accidents during interstate flights because Congress intended uniformity in rules governing air travel safety across all states; thus requiring plaintiffs to prove willful misconduct or gross negligence as per federal regulations rather than simply relying on contractual obligations under state laws.

In the dissenting opinion for the case of First National Bank of Chicago v. United Airlines, Inc., Justice Robert H. Jackson disagreed with the majority's ruling that a wrongful death action could be brought in federal court based on diversity jurisdiction even though such an action was not recognized under Illinois law where the accident occurred. He argued that this decision violated principles of federalism and comity by allowing a plaintiff to bypass state law restrictions simply by filing suit in federal court instead. Furthermore, he contended that it undermined uniformity and predictability in tort law because outcomes would depend on whether cases were filed in state or federal court rather than being governed by consistent legal rules. Finally, he expressed concern about forum shopping and potential unfairness to defendants who might face different liability standards depending on which court heard their case.