In the 1906 case of Heyman v. Southern Railway Company, the U.S. Supreme Court ruled in favor of Southern Railway Company, dismissing a claim made by Heyman for damages due to alleged negligence on part of the railway company. The plaintiff had purchased a ticket from New York to Charleston and was injured when his train derailed near Savannah due to an obstruction on the track caused by another derailment that occurred earlier. The court held that since there was no evidence showing that Southern Railway could have known about or prevented this accident within reasonable time after it happened, they were not liable for negligence under Georgia law which governed this issue at that time.

In the dissenting opinion for Heyman v. Southern Railway Company, the justice argued that the court majority had erred in its interpretation of liability and negligence laws. The dissenting view held that there was sufficient evidence to suggest that Southern Railway Company may have been negligent in their duty of care towards Mr. Heyman, which resulted in his injury while working on a construction project for them. This perspective emphasized that it should be up to a jury to decide whether or not negligence occurred based on all available evidence rather than having this decision made by judges alone during preliminary stages of litigation. Furthermore, they believed an employer's responsibility extends beyond providing safe tools and equipment but also includes ensuring employees are adequately trained and supervised - areas where they felt Southern Railway potentially fell short.