In the 1896 case of Martin v. Atchison, Topeka and Santa Fe Railroad Company, the U.S Supreme Court ruled in favor of the railroad company. The plaintiff, Martin had sued for damages after a train accident that resulted in personal injury. He alleged negligence on part of the railroad company due to excessive speed at which their train was moving when it collided with his wagon at a public crossing. However, evidence showed that he did not stop or look for an approaching train before attempting to cross as required by Kansas law (the state where incident occurred). The court held that despite any potential negligence by the railroad company, Martin's own failure to take precautionary measures contributed significantly towards his injuries thereby absolving AT&SF from liability under contributory negligence doctrine prevalent during this period.

The dissenting opinion in the case of Martin v. Atchison, Topeka and Santa Fe Railroad Company argued that the majority's decision to uphold a Kansas statute requiring railroads to provide equal accommodations for all passengers was an overreach of state power. The dissent contended that this law interfered with interstate commerce by imposing undue burdens on railroad companies operating across state lines. It also suggested that such laws could lead to absurd results if each state were allowed to set its own rules regarding train accommodations, potentially resulting in inconsistent and impractical requirements for railroads. Furthermore, it questioned whether states had any legitimate interest or authority in regulating private business practices related solely to comfort and convenience rather than safety or public welfare concerns.