In the 1930 case Flynn, Executor, v. New York, New Haven & Hartford Railroad Company, the U.S Supreme Court was tasked with determining whether a railroad company could be held liable for injuries sustained by an employee who fell from a moving train. The plaintiff argued that the defendant had failed to provide safe working conditions as required under federal law. However, it was revealed during trial proceedings that the injured party had been drinking alcohol prior to his shift and was likely intoxicated at the time of his accident. This led to questions about contributory negligence and its impact on employer liability in workplace accidents. The court ultimately ruled in favor of the defendant (the railroad company), holding that while employers are indeed responsible for maintaining safe work environments under federal law, employees also have a duty not to endanger themselves or others through reckless behavior such as intoxication on duty. Therefore, despite potential shortcomings in safety measures provided by their employer - if an employee's own negligent actions contribute significantly towards their injury then they may not be entitled to damages.

In the dissenting opinion for Flynn, Executor v. New York, Haven & Hartford Railroad Company (1930), Justice Stone argued that the majority's decision was inconsistent with previous rulings of the court and violated principles of federalism. He contended that it was not within the jurisdiction of a federal court to decide on matters related to state law unless there is an explicit provision in federal legislation or constitution allowing them to do so. In this case, he believed that Connecticut’s Workmen’s Compensation Act should be interpreted by Connecticut courts rather than being decided upon by a Federal Court as it pertains directly to state law. Furthermore, he disagreed with how broadly his colleagues had interpreted Congress' intent when passing laws governing railroad workers' compensation claims and felt they were overstepping their boundaries by applying these laws too expansively.