In the case of Landers v. National Railroad Passengers Corporation et al., 1987, plaintiff Robert Landers sued his employer, Amtrak (National Railroad Passenger Corporation), for alleged violations of the Federal Employers' Liability Act (FELA). He claimed that he had been injured due to negligence on part of Amtrak and sought damages. The trial court initially ruled in favor of Landers but this decision was overturned by the Court of Appeals which held that there wasn't sufficient evidence to prove negligence on part of Amtrak. When appealed to the Supreme Court, it affirmed the lower court's ruling stating that a FELA claim requires proof not just that an injury occurred during employment or as a result thereof but also clear demonstration that some act or omission by the employer constituted negligence leading directly to said injury.

In the dissenting opinion for Landers v. National Railroad Passengers Corporation, it was argued that the majority's decision to dismiss Mr. Landers' claim under Title VII of the Civil Rights Act of 1964 was incorrect because they failed to consider his allegations in their entirety and instead focused on individual parts separately. The dissenting justices believed that if all allegations were considered together, there would be enough evidence to suggest a discriminatory motive behind Amtrak’s actions against Mr. Landers due to his race and age which could have led him being denied promotions or pay raises unfairly compared with younger, white employees who had less experience or qualifications than he did.