In the 1945 case Gange Lumber Co. v. Rowley and Department of Labor & Industries of the State of Washington, the U.S Supreme Court ruled in favor of Rowley and the Department of Labor & Industries. The dispute arose when Gange Lumber Company challenged a compensation award granted to an injured employee under Washington's Industrial Insurance Act, arguing that it was not liable for injuries sustained outside its premises during lunch breaks. However, considering that employees were required to eat their meals on site due to remote location and lack of facilities nearby, Justice Murphy delivered an opinion stating that such injuries could be considered as occurring within course and scope employment hence compensable under state law.

In the dissenting opinion for Gange Lumber Co. v. Rowley and Department of Labor & Industries of the State of Washington, it was argued that there is a clear distinction between an 'accident' and an 'occupational disease.' The justice disagreed with the majority's interpretation that occupational diseases fall under accidents in workers' compensation laws. He contended that if lawmakers intended to include occupational diseases within accident coverage, they would have explicitly stated so in legislation. Furthermore, he pointed out inconsistencies in previous court rulings on similar cases where some were awarded compensation while others weren't due to differing interpretations of what constitutes as an accident or occupational disease. This lack of clarity leads to unfair treatment among workers suffering from work-related illnesses who deserve equal protection under law regardless whether their conditions are classified as accidents or not.