In the case of Meisukas v. Greenough Red Ash Coal Company, 1916, the U.S Supreme Court was tasked with determining whether a coal company could be held liable for injuries sustained by an employee due to negligence on part of another employee. The plaintiff, Mr. Meisukas, had been injured while working in one of the defendant's mines when a fellow worker negligently caused a rock to fall onto him from above. He sued for damages under Pennsylvania’s Employer Liability Act which allowed employees to sue their employers if they were injured as result of negligence by fellow workers or supervisors. The court ruled in favor of the defendant and dismissed Mr.Meisukas' claim stating that his injury did not meet criteria set out in Pennsylvania’s Employer Liability Act because it was not caused directly by any act or omission on part of employer but rather resulted from negligent actions taken independently by another worker without direct involvement or oversight from employer.

The dissenting opinion in the case of Meisukas v. Greenough Red Ash Coal Company argued that the plaintiff, a miner injured while working for the defendant company, should have been allowed to present his case before a jury. The justice believed that there was sufficient evidence to suggest negligence on part of the coal company which led to unsafe working conditions and ultimately resulted in injury for Meisukas. He contended that it was not within their purview as Supreme Court justices to decide whether or not such negligence existed; rather, this decision should be left up to a jury trial where all facts and testimonies could be thoroughly examined. This justice felt strongly about preserving an individual's right to trial by jury especially when dealing with matters related directly towards worker safety regulations and employer liability.