In the case of Great Northern Railway Company v. Alexander, Administrator of Hall (1917), the U.S Supreme Court ruled in favor of the railway company. The dispute arose when a train owned by Great Northern Railway collided with a wagon driven by Mr. Hall, resulting in his death. His administrator, Alexander, sued for damages alleging negligence on part of the railway company's employees who failed to give adequate warning signals at an intersection where visibility was limited due to snow banks and other obstructions. The court held that while it is true that railroads have a duty to exercise reasonable care under all circumstances for safety at crossings, this does not mean they are insurers against accidents which may occur thereon despite their best efforts and precautions taken within reasonableness. The evidence showed that bell ringing and whistle blowing were done as required by law; therefore no negligence could be attributed to them regarding signaling or speed control since they complied with statutory requirements. Furthermore, considering conditions such as weather or time should be left up to juries rather than being decided upon rigid rules set forth by courts because these factors can vary greatly from case-to-case basis making it impossible for any one rule applicable universally.

In the dissenting opinion for Great Northern Railway Company v. Alexander, Administrator of Hall (1917), Justice Holmes argued that the majority's decision was inconsistent with previous rulings and failed to consider important factors in determining liability. He pointed out that under common law principles, a company is not liable for an employee's negligence if it did not have control over their actions or could not foresee the harm caused by them. In this case, he believed that there was no evidence showing that the railway company had any control over its employees' actions leading to Mr. Hall’s death or could predict such a tragic outcome from those actions. Therefore, according to him, imposing liability on the railway company would be unjust and contrary to established legal principles.