In the case Middleton v. Texas Power & Light Company (1918), the U.S Supreme Court ruled in favor of Texas Power & Light Company, rejecting a claim brought by J.W. Middleton's widow for damages following his death due to an electrocution accident at work. The court held that Mrs. Middleton could not recover damages from her husband’s employer because Mr. Middleton was aware of the dangers associated with his job and had assumed those risks when he accepted employment as a lineman working on high voltage power lines, thus applying the doctrine of assumption of risk which bars or reduces a plaintiff's right to recovery against negligent acts if they voluntarily expose themselves to danger knowing there is substantial and unreasonable risk involved.

In the dissenting opinion for Middleton v. Texas Power & Light Company, it was argued that the majority's decision to uphold a state law allowing corporations to be sued in any county where they do business violated due process rights under the Fourteenth Amendment. The dissent contended that this interpretation of jurisdictional rules unfairly burdened businesses and could potentially lead to abuse by plaintiffs seeking favorable venues for their lawsuits. Furthermore, it was suggested that such broad interpretation of jurisdictional reach might discourage companies from doing business in multiple counties or states out of fear of being subject to litigation in unfavorable jurisdictions. This view held that due process should guarantee corporations reasonable protections against arbitrary and unfair legal proceedings, including venue selection.