In the 1904 case Johnson v. Southern Pacific Company, the U.S Supreme Court ruled in favor of the defendant, Southern Pacific Company. The plaintiff, Mr. Johnson had sued for damages after he was injured while working on a railroad construction project managed by his employer, Southern Pacific Company. He claimed that his injuries were due to negligence on part of his employer who failed to provide safe working conditions and adequate equipment maintenance which led to an accident causing him severe physical harm. The court however found that there was no evidence proving negligence from the company's side as they had adhered strictly to safety regulations and guidelines set forth by law for such projects at all times during their operations including when the incident occurred. Furthermore, it was also determined that Mr.Johnson himself had been negligent as he did not exercise reasonable care or caution while performing his duties which contributed significantly towards causing this unfortunate event. Therefore based upon these findings,the court decided against awarding any compensation or damages to Mr.Johnson concluding instead that both parties shared equal responsibility in bringing about this situation thereby dismissing all claims made against Southern Pacific Company.

In the dissenting opinion for Johnson v. Southern Pacific Company, it was argued that the court majority erred in their interpretation of liability under federal law. The dissent contended that the plaintiff's injury resulted from a violation of his statutory rights and thus, he should be entitled to damages regardless of whether negligence could be proven on part of the defendant company or not. They maintained that any failure to comply with safety regulations constituted a breach which automatically rendered an employer liable for injuries sustained by employees as a result thereof. This view rejected the majority’s stance requiring proof of negligence and causation between said negligence and injury suffered by an employee before liability can be established against an employer under federal laws governing railway worker safety.