In the case of Kansas City Southern Railway Company v. Van Zant, 1922, the U.S Supreme Court ruled in favor of Kansas City Southern Railway Company. The dispute arose when a railway employee was injured while working on an interstate train due to alleged negligence by his employer. He filed suit under Federal Employers' Liability Act (FELA) but died before trial completion and his wife continued with the claim as administratrix of her husband's estate. The lower court awarded damages to Mrs.Van Zant based on FELA provisions which were appealed by the company arguing that it should have been tried under state law instead of federal law because at the time of injury, no interstate commerce was being conducted. The Supreme Court reversed this decision stating that even though there wasn't any active transportation across state lines at that moment, since he was employed for such work and got injured during it; hence FELA applied here making it a federal issue rather than a state one.

In the dissenting opinion for Kansas City Southern Railway Company v. Van Zant, it was argued that the majority's decision to uphold a state law requiring railway companies to provide separate accommodations based on race violated both the due process and equal protection clauses of the Fourteenth Amendment. The dissent contended that this ruling effectively endorsed racial segregation and discrimination, which contradicted fundamental principles of equality under U.S. law. It also suggested that such laws were not only morally wrong but economically inefficient as they forced railroads to incur unnecessary costs in providing separate facilities when one would suffice for all passengers regardless of their race or color.