In the case of Louisville and Nashville Railroad Company v. Schmidt, 1899, the U.S Supreme Court ruled in favor of the railroad company. The dispute arose when Mr. Schmidt sued for damages after his wife was killed at a railway crossing by one of their trains. He claimed that there were no warnings or barriers to indicate an approaching train which led to her death. However, evidence showed that she had crossed these tracks regularly and was familiar with them but on this particular day chose not to stop and look for any incoming trains as she usually did before crossing over - thus contributing significantly towards her own demise. The court held that while it is indeed a duty of railroads to provide reasonable warning signals at crossings, they are not insurers against accidents nor can they be expected to maintain perfect safety measures at all times especially if individuals do not exercise due caution themselves. This ruling set precedence in personal injury law where contributory negligence (where plaintiff's own negligence played part in causing harm) could completely bar recovery if it contributed even slightly ('slightest degree rule') towards their injuries.

In the dissenting opinion for Louisville and Nashville Railroad Company v. Schmidt, Justice Harlan argued that the majority's decision was inconsistent with previous rulings of the Court regarding interstate commerce regulation. He contended that states should retain their power to regulate rates charged by railroads within their borders unless Congress explicitly preempts this authority. Harlan believed that allowing federal courts to intervene in state rate-setting would undermine state sovereignty and disrupt a balance of powers between federal and state governments. Furthermore, he expressed concern about potential negative impacts on local businesses if they were subjected to potentially higher rates set by out-of-state corporations without any recourse through their own state government regulations or courts.