In the case of Jennings v. Philadelphia, Baltimore and Washington Railway Company (1910), the U.S Supreme Court ruled in favor of the railway company. The plaintiff, Jennings, was a passenger on one of the defendant's trains when he was injured due to an alleged defect in a seat that caused it to collapse under him. He sued for damages claiming negligence on part of the railway company for not maintaining its equipment properly which led to his injury. However, upon review by Justice Holmes and other members of court, it was determined that there wasn't sufficient evidence presented by Jennings proving negligence or any fault from the railway company leading directly to his injuries. Therefore, they concluded that no liability could be imposed on them based solely on their ownership status without proof showing they were aware or should have been aware about such defects but failed to act accordingly.

In the dissenting opinion for Jennings v. Philadelphia, Baltimore and Washington Railway Company, it was argued that the majority's decision to hold a railway company liable for injuries sustained by an employee while on duty was erroneous. The dissenting justices believed that the plaintiff had assumed all risks associated with his employment when he accepted his job as a brakeman. They contended that there were inherent dangers in such work which could not be entirely eliminated by any precautions taken by employers. Furthermore, they pointed out that federal law did not require railroads to provide automatic couplers at both ends of each car; thus, it would be unfair to penalize them for failing to do so. In their view, if Congress intended railways should bear this responsibility regardless of whether or not they complied with existing safety regulations then it should amend the law accordingly rather than leaving interpretation up to courts.