In the 1941 case of Miles et al. v. Illinois Central Railroad Co., the U.S Supreme Court ruled in favor of the railroad company, dismissing a claim for damages by two African American women who were ejected from a train car designated "for white people only". The plaintiffs argued that their ejection was unjust and violated their rights under federal law, specifically citing an act passed by Congress in 1875 which prohibited racial discrimination on public conveyances. However, this Act had been declared unconstitutional by the Supreme Court in 1883. Therefore, it could not serve as grounds for their lawsuit against Illinois Central Railroad Company. The court held that since there was no existing federal statute barring segregation on interstate trains at that time (the Civil Rights Act would not be enacted until over two decades later), they couldn't provide relief to plaintiffs based on alleged violation of such non-existent laws or regulations. This decision underscored how deeply ingrained racial segregation policies were within American society during this period and highlighted the legal challenges faced by those seeking to challenge these discriminatory practices.

In the dissenting opinion for Miles et al. v. Illinois Central Railroad Co., Justice Frank Murphy argued that the majority's decision was a departure from established principles of law and justice, particularly in relation to negligence cases involving multiple defendants. He contended that it should not be necessary for an injured party to prove which specific act of negligence caused their injury when there are multiple negligent parties involved; instead, all negligent parties should share responsibility unless they can prove their actions did not contribute to the harm suffered by the plaintiff. This principle is known as "joint and several liability." In this case, he believed both railroad companies were at fault due to their failure in providing safe working conditions leading up to Miles' death, regardless of which company's train actually struck him.