In the 1915 case of Loomis v. Lehigh Valley Railroad Company, the U.S. Supreme Court ruled in favor of the defendant, Lehigh Valley Railroad Company. The plaintiff, Mr. Loomis, was a passenger on one of their trains when he suffered injuries due to an accident caused by negligence from another railroad company's employees who were operating a different train on shared tracks. He sued for damages but his claim was denied because it was found that there had been no breach of duty or contract by Lehigh Valley Railroad as they had not contributed to nor could have prevented the accident caused by another company's negligence.

In the dissenting opinion for Loomis v. Lehigh Valley Railroad Company, it was argued that the majority's decision to hold a railroad company liable for injuries sustained by an employee due to negligence of another employee contradicted previous rulings and interpretations of federal law. The dissenting justices contended that under the Federal Employers' Liability Act (FELA), employers should only be held responsible if they had knowledge or reason to know about potential risks or dangers in their workplace, which wasn't proven in this case. They also emphasized that FELA intended to protect workers from employer negligence, not necessarily from all harm caused by fellow employees during work hours. Thus, they believed holding companies accountable without clear evidence of neglectful oversight would set a dangerous precedent and potentially burden businesses with unfair liability.