The U.S. Supreme Court case Illinois Central Railroad Company v. Edwards in 1906 revolved around a dispute over the liability of an employer for injuries sustained by its employee while on duty. The plaintiff, Edwards, was injured when he fell from a platform of a car due to the sudden jerk caused by another car's collision with his train at night time. He sued Illinois Central Railroad Company claiming negligence on their part as they failed to provide him with safe working conditions and adequate lighting facilities during nighttime work hours which led to his accident. However, the court ruled in favor of the defendant (Illinois Central Railroad Company), stating that it was not negligent because there were no laws or regulations requiring them to provide lights during such operations at that time period and thus they had fulfilled their obligation towards providing reasonably safe working conditions for employees under existing standards and norms.

In the dissenting opinion for Illinois Central Railroad Company v. Edwards, it was argued that the majority's decision to uphold a state law requiring railroads to pay damages for livestock killed on their tracks, even if they were not negligent, violated the Fourteenth Amendment's due process clause. The dissenting justices believed that this law unfairly penalized railroad companies and amounted to an unconstitutional taking of property without just compensation. They contended that while states have broad powers to regulate businesses in the public interest, these powers do not extend so far as allowing them to impose arbitrary and unreasonable liabilities on specific industries or classes of individuals. In their view, such laws are essentially discriminatory and violate fundamental principles of fairness underpinning American constitutional jurisprudence.