In the 1901 case of Knoxville Iron Company v. Harbison, the U.S. Supreme Court ruled in favor of Harbison, who had sued for damages after being injured while working at a furnace owned by Knoxville Iron Company. The company argued that they were not liable because Harbison was aware of the risks involved and chose to work anyway - an argument known as "assumption of risk". However, the court found that this doctrine did not apply because it was unreasonable to expect workers to refuse employment due to potential hazards inherent in their line of work. Furthermore, it was established that employers have a duty to provide safe working conditions for their employees regardless if they are aware or unaware about any potential dangers associated with their job roles.

In the dissenting opinion for Knoxville Iron Company v. Harbison, it was argued that the majority's decision to uphold a Tennessee law requiring companies to pay their employees in legal tender rather than company scrip was an overreach of judicial power. The dissent contended that this state law did not violate any provisions of the U.S Constitution and should be upheld under states' rights to regulate commerce within their borders. They believed that if a worker willingly accepted payment in company scrip as part of his employment contract, then he should not later be able to sue for wages in cash. This view held that such contracts were private matters between employer and employee, outside the purview of government intervention unless there is clear evidence of coercion or fraud involved.