In the 1926 case of Lawrence et al. v. St. Louis-San Francisco Railway Company, the U.S Supreme Court ruled in favor of the railway company, dismissing a claim by two employees who sought compensation for injuries sustained while working on an interstate train that was temporarily stationary due to mechanical issues. The court held that under Federal Employers' Liability Act (FELA), workers are only entitled to damages if their injury occurred during transportation or activities directly related to it; maintenance work does not fall within this category even if performed on an interstate train. Therefore, since Lawrence and his colleague were injured while performing repair tasks rather than actual transportation duties, they were not eligible for compensation under FELA.

In the dissenting opinion for Lawrence et al. v. St. Louis-San Francisco Railway Company, Justice McReynolds disagreed with the majority's decision to uphold a lower court ruling that denied compensation to railway workers injured on the job due to negligence by their employer under Federal Employers' Liability Act (FELA). He argued that FELA was designed specifically to protect railroad employees from harm caused by negligent employers and should be interpreted broadly in favor of these workers. The justice believed that any ambiguity in interpreting FELA should not lead towards limiting its scope but rather expanding it so as to ensure maximum protection for railway employees against injuries at work resulting from an employer’s negligence or fault.