In the 1916 case of Lehigh Valley Railroad Company v. Barlow, the United States Supreme Court ruled in favor of the railroad company. The dispute arose when Mr. Barlow was injured while working for Lehigh Valley Railroad and sought compensation under New Jersey's Employer’s Liability Act which allowed employees to sue employers directly for injuries sustained on the job due to negligence or wrongful acts by fellow employees. However, at that time he was also receiving benefits from a relief fund established by his employer as part of an employment contract agreement which stated that acceptance of these benefits would waive any right to sue under state law. The court held that this contractual arrangement did not violate public policy nor did it deprive Mr. Barlow of his rights without due process under Fourteenth Amendment since he voluntarily agreed to it upon employment and could have chosen not to accept such benefits if he wished so as per freedom-of-contract principles prevailing during early 20th century jurisprudence. Therefore, despite being injured on duty due to alleged negligence by another employee, Mr.Barlow couldn't claim additional damages from his employer because he had already accepted monetary aid from their relief fund thereby waiving off any further legal claims against them according this specific provision in their mutual contract agreement upheld validly by Supreme Court ruling.

In the dissenting opinion for Lehigh Valley Railroad Company v. Barlow, Justice Holmes disagreed with the majority's ruling that a railroad company could be held liable for injuries sustained by an employee due to negligence of fellow employees under Federal Employers' Liability Act (FELA). He argued that FELA was not intended to impose liability on employers in such cases and should only apply when there is direct negligence from the employer itself. The justice believed that this interpretation would lead to unjust outcomes where companies are unfairly penalized for actions beyond their control or foresight. Furthermore, he contended that it was inappropriate and unwise to interpret FELA as changing common law rules regarding vicarious liability without clear indication from Congress.