In the 1893 case of Martin's Administrator v. Baltimore and Ohio Railroad Company, the U.S Supreme Court ruled on a dispute involving liability for an accident that occurred in West Virginia. The plaintiff was the administrator of John Martin's estate, who died while working as a brakeman for the railroad company when he fell from a moving train due to alleged negligence by his employer. The defendant argued that under West Virginia law at that time, employers were not liable for injuries or death caused by fellow employees' negligence during work hours. However, this contradicted federal laws which held companies accountable in such situations. The court had to decide whether state or federal law should apply since it involved interstate commerce - trains crossing state lines regularly - making it potentially subject to both jurisdictions. In its decision, the Supreme Court upheld states' rights over federal jurisdiction in matters concerning local activities like railway operations within their borders unless Congress specifically legislated otherwise. This ruling affirmed that although railroads engaged in interstate commerce are federally regulated entities; they are also subject to individual state laws regarding employee safety and compensation unless there is explicit preemption by Congress.

In the dissenting opinion for Martin's Administrator v. Baltimore and Ohio Railroad Company, the justice argued that the railroad company should be held liable for damages caused by its negligence. The justice disagreed with the majority's interpretation of federal law, which they believed did not impose a duty on railroads to ensure safe passage across their tracks at public crossings. They contended that this interpretation was inconsistent with common law principles of liability and failed to adequately protect public safety. Furthermore, they asserted that it is unreasonable to expect individuals crossing railroad tracks to always anticipate potential dangers posed by approaching trains due to factors such as noise from other sources or visual obstructions along the track. Therefore, in cases where an individual is killed while crossing a railway due to no fault of their own but because of neglectful actions taken by employees of a railway company - like failing signal an approach or maintain proper lookouts - then those companies must bear responsibility for any resulting harm.