In the case of James Stewart & Co. v. Sadrakula, 1939, the U.S Supreme Court ruled in favor of Sadrakula, overturning a decision by New York's highest court that had absolved a contractor from liability for an accident at its construction site which resulted in death. The deceased was not directly employed by James Stewart & Co., but rather worked for an independent subcontractor on-site when he fell and died due to inadequate safety measures provided by the main contractor. The Supreme Court held that under Section 200 of New York Labor Law, general contractors have non-delegable duty to maintain safe working conditions regardless if workers are employed directly or through subcontractors; thus making them liable for any accidents caused due to unsafe conditions.

In the dissenting opinion for James Stewart & Co. v. Sadrakula, it was argued that the majority's decision to allow a state law to supersede federal law in determining liability for injuries sustained on federally owned property contradicted previous Supreme Court rulings and undermined federal sovereignty. The dissenting justices believed that while states have the power to regulate safety conditions within their borders, this authority should not extend to properties owned by the U.S government as they are under exclusive jurisdiction of Congress according to Article I, Section 8 of Constitution. They contended that allowing state laws such as New York’s Scaffold Law (which held contractors liable for workers’ injuries) apply on federal lands would result in inconsistent regulations across different states and could potentially hinder national projects or activities carried out on these properties.