In the 1906 case of Green v. Chicago, Burlington and Quincy Railway Company, plaintiff William Green sued the railway company for damages after he was injured while working as a brakeman. The Supreme Court ruled in favor of the defendant, stating that it was not liable for injuries sustained by employees due to their own negligence or recklessness. The court found that there were no defects in equipment or failure on part of the employer to provide safe conditions which could have contributed to Green's injury; rather his actions led directly to his accident. This ruling reinforced an important principle: employers are not automatically responsible for all workplace accidents but only those caused by unsafe conditions they failed to address.

In the dissenting opinion for Green v. Chicago, Burlington and Quincy Railway Company, it was argued that the court majority had erred in its interpretation of liability under the Safety Appliance Act. The dissent maintained that Congress intended to impose absolute liability on railroads for injuries resulting from defective equipment, regardless of negligence or fault on part of the railroad company. They believed this strict interpretation would better serve public safety by encouraging companies to maintain their equipment properly. Furthermore, they disagreed with the majority's view that a worker’s contributory negligence could reduce a company’s responsibility under this law; instead arguing such an approach undermined Congressional intent behind passing such legislation aimed at protecting workers' safety.