In the case of Illinois Central Railroad Company v. Brown in 1894, the U.S Supreme Court ruled on a dispute involving an injury claim by a railroad worker. The plaintiff, Mr. Brown, was injured while working for the Illinois Central Railroad Company and sought compensation for his injuries under Mississippi law which held employers liable for injuries caused by fellow employees' negligence if they were acting within their scope of employment at the time of causing harm to another employee. The company argued that this state law conflicted with federal laws regulating interstate commerce as it imposed undue burdens on companies involved in such activities. The Supreme Court disagreed with this argument and upheld Mississippi's employer liability law ruling that it did not conflict with federal regulations governing interstate commerce because its application was general rather than specific to businesses engaged in such trade only. It further stated that states have inherent powers to regulate matters concerning health, safety and welfare of their citizens including workplace safety rules unless expressly prohibited by Congress or when there is clear evidence showing these rules interfere directly with operations of interstate commerce.

In the dissenting opinion for Illinois Central Railroad Company v. Brown, it was argued that the majority's decision to hold the railroad company liable for damages caused by a fire started by sparks from its locomotive was unjustified. The dissenting justices believed that there was insufficient evidence to prove negligence on part of the railroad company and contended that fires were an inevitable risk associated with operating steam-powered trains during this era. They also pointed out that other potential sources of ignition existed in close proximity to where the fire broke out, suggesting it could have been caused by factors outside of their control. Furthermore, they disagreed with imposing liability without proof of negligence because such a ruling would place an undue burden on railroads and potentially hinder economic development.