In the 1905 case of Looney v. Metropolitan Railroad Company, the United States Supreme Court ruled in favor of the defendant, Metropolitan Railroad Company. The plaintiff, Mr. Looney, had sued for damages after he was injured while trying to board a moving streetcar operated by the railroad company in Washington D.C., alleging negligence on part of the company's employees. However, evidence showed that Mr. Looney had ignored warnings from both a police officer and an employee of the railroad not to attempt boarding while it was still moving due to safety concerns; thus his injuries were largely self-inflicted as a result of his own recklessness and disregard for safety instructions provided at that time. The court held that although companies are required to exercise reasonable care towards passengers' safety under common law principles governing carriers' liability towards passengers - this duty does not extend so far as protecting individuals against their own reckless behavior or imprudence when such actions directly contribute toward causing harm they suffer subsequently. Therefore, since Mr.Looney's injury resulted primarily from his own negligent conduct rather than any failure on part of Metropolitan Railroad Company or its staff - no grounds existed upon which they could be held liable for damages sought by him through this lawsuit.

The dissenting opinion in the Looney v. Metropolitan Railroad Company case argued that the court majority erred in its interpretation of Washington D.C.'s street railway act, which required companies to "give transfers for a continuous ride from any point on their lines or extensions thereof to any other point." The dissent contended that this provision should be interpreted as requiring railroads to provide passengers with free transfer tickets enabling them to continue their journey without additional charge, regardless of whether they had initially boarded at an intersection between two routes. It was also pointed out by the dissenters that if a passenger were forced off at an intersection and made to pay another fare due to lack of direct service, it would not constitute a 'continuous ride'. They believed this interpretation better aligned with legislative intent and public interest.