In the 1916 case of Illinois Central Railroad Company v. Peery, the U.S. Supreme Court ruled in favor of the railroad company, reversing a decision by the Tennessee Supreme Court that had awarded damages to Mr. Peery for injuries he sustained while working as an employee for Illinois Central Railroad Company. The court held that under federal law (the Federal Employers' Liability Act), employees could only recover damages if their injury was due to negligence on part of their employer and not because they voluntarily assumed risk associated with their job duties or were negligent themselves. In this case, it was found that Mr.Peery's injuries resulted from his own failure to use available safety equipment rather than any negligence on part of his employer.

In the dissenting opinion for Illinois Central Railroad Company v. Peery, it was argued that the majority's decision to uphold a verdict in favor of an injured employee under the Federal Employers' Liability Act (FELA) was incorrect. The dissent contended that there wasn't sufficient evidence presented at trial to prove negligence on part of the railroad company which led directly to Mr. Peery’s injury as required by FELA. They believed that any negligence on behalf of other employees should not be attributed to their employer without clear proof showing how such actions contributed directly and proximately towards causing harm or damage suffered by plaintiff, which they felt was lacking in this case.