In the 1957 case Honeycutt v. Wabash Railway Co., the U.S Supreme Court ruled in favor of Wabash Railway Co., reversing a decision by the Missouri Supreme Court. The plaintiff, Honeycutt, was an employee of Wabash who suffered injuries while working on a railroad car and subsequently sued for damages under the Federal Employers' Liability Act (FELA). He claimed that his injury resulted from negligence on part of his employer as they failed to provide him with safe work conditions. However, it was found that he had not been following safety rules at the time of his accident which contributed to his own injury. The court held that under FELA, if an injured worker's own negligence played any role in causing their injuries, even if there was also negligence by their employer or co-workers contributing to those injuries; then they could not recover full damages but only partial ones based on comparative fault principles.

In the dissenting opinion for Honeycutt v. Wabash Railway Co., it was argued that the majority's decision to uphold a lower court ruling, which found in favor of an injured railway worker under the Federal Employers' Liability Act (FELA), failed to consider important aspects of negligence law. The dissent contended that there was no evidence presented at trial showing that the railroad company had breached its duty of care towards its employee or acted negligently in any way. Furthermore, they disagreed with how causation was determined by both courts and believed this case should have been dismissed due to lack of proof on these key elements required for a successful negligence claim under FELA. They also expressed concern about potential implications this ruling could have on future cases involving similar circumstances, fearing it may set a precedent where employers are held liable without clear evidence proving their fault.