In the 1901 case of Groeck v. Southern Pacific Railroad Company, the plaintiff, Mr. Groeck, sued the railroad company for damages after he was injured while working as a brakeman on one of their trains. The accident occurred when a defective brake handle broke off in his hand causing him to fall from the train and sustain injuries. The Supreme Court ruled that under federal law at that time (the Federal Employers Liability Act), an employer could be held liable for injuries sustained by its employees due to faulty equipment or negligence on part of other employees but not if it resulted from employee's own negligence or assumption of risk associated with job duties. However, this ruling did not absolve employers completely; they were still required to provide safe work environments and properly maintained equipment for their workers' use.

The dissenting opinion in the Groeck v. Southern Pacific Railroad Company case argued that the plaintiff, Mr. Groeck, was not negligent and therefore should not bear any responsibility for his injuries sustained during a train collision while he was working as a brakeman for Southern Pacific Railroad Company. The dissenting justices believed that there were sufficient safety measures available at the time which could have prevented such an accident from occurring if they had been properly implemented by the railroad company. They contended that it was unreasonable to expect workers like Mr. Groeck to anticipate every potential danger or malfunction on their own without adequate training or safeguards provided by their employer. Therefore, they felt it unjust to hold him accountable for his injuries when he was merely performing his duties under dangerous conditions created by negligence of his employer.