In the case of Lang, Administratrix of Lang v. New York Central Railroad Company (1920), the U.S. Supreme Court ruled in favor of the defendant, New York Central Railroad Company. The plaintiff was seeking damages for negligence under federal law after her husband died while working on a railroad track owned by the company. However, it was found that Mr.Lang had been negligent himself and his death resulted from his own failure to heed safety regulations set forth by his employer - he did not use a safety device provided to him which would have prevented his fatal accident. Therefore, despite Mrs.Lang's claim that her husband’s supervisor should have enforced these rules more strictly or taken additional precautions due to dangerous conditions at work site, no liability could be attributed to the company as they had fulfilled their duty in providing necessary safety equipment and instructions.

In the dissenting opinion for Lang v. New York Central Railroad Company, Justice Oliver Wendell Holmes Jr. argued that the railroad company should not be held liable for Mrs. Lang's husband's death because he voluntarily assumed the risk associated with his job as a brakeman on freight trains when he accepted employment from the company. He believed that Mr. Lang was aware of and understood these risks, which included potential injury or death due to accidents like derailments or collisions, and chose to accept them in exchange for his wages. Therefore, according to Justice Holmes' view of contract law principles and worker-employer relationships at this time period in history (1920), it would be unjust to hold an employer responsible for injuries or deaths resulting from known occupational hazards willingly accepted by employees.