The U.S. Supreme Court case Market Street Cable Railway Company v. Rowley in 1894 revolved around a dispute between the railway company and an individual named Rowley, who was injured while using the railway's services. The court had to decide whether or not the railway company could be held liable for injuries sustained by passengers due to negligence on part of its employees under California state law. The Supreme Court ruled in favor of Rowley, stating that as per common carrier laws, companies are responsible for ensuring passenger safety during transit and must exercise utmost care and diligence in doing so; any failure leading to injury makes them liable for damages unless they can prove that they took all necessary precautions against foreseeable risks.

In the dissenting opinion for Market Street Cable Railway Company v. Rowley, Justice Brewer argued that the majority's decision to uphold a state law requiring railway companies to compensate employees injured on the job was an overreach of judicial power. He contended that it is not within the purview of courts to determine what constitutes reasonable compensation for injuries sustained in employment accidents; rather, this should be left up to negotiation between employers and employees or their representatives. Furthermore, he expressed concern about potential abuse of such laws by unscrupulous individuals seeking unjust enrichment at businesses' expense. Finally, he warned against setting a precedent whereby courts could interfere with private contractual relationships based on subjective notions of fairness or public policy considerations.