In the case of Johnson, Administratrix v. New York, New Haven & Hartford Railroad Co., 1952, the U.S Supreme Court ruled in favor of the railroad company. The plaintiff was seeking damages for her husband's death caused by a collision between his car and one of the defendant’s trains at a grade crossing in Connecticut. However, it was found that Mr. Johnson had ignored warning signals before attempting to cross the tracks which led to his fatal accident. The court held that under Connecticut law and Federal Employers' Liability Act (FELA), contributory negligence - where an injured party is partially responsible for their own injuries - could completely bar recovery if it contributed even slightly to causing harm or damage suffered by them; hence Mrs.Johnson's claim was denied as her husband had been negligent himself.

In the dissenting opinion for Johnson v. New York, New Haven & Hartford Railroad Co., Justice Frankfurter argued that the majority's decision to allow a state court to decide on matters of federal law was an overreach of judicial power and undermined the authority of Congress. He contended that it is not within the purview of courts to determine whether or not a claimant has rights under federal laws; rather, this responsibility lies with administrative agencies as designated by Congress. In his view, allowing state courts such jurisdiction could lead to inconsistent interpretations and applications of federal law across different states. Furthermore, he expressed concern about potential prejudice against railroad companies due to local bias in favor of injured workers in these cases.