In the 1933 case of Miller, Administrator v. Union Pacific R.R. Co., the U.S Supreme Court ruled in favor of Union Pacific Railroad Company (Union Pacific). The dispute arose when a train owned by Union Pacific collided with an automobile at a crossing, resulting in two deaths and one injury. The administrator of the deceased's estates sued for damages on grounds that Union Pacific was negligent because it failed to provide adequate warning signals at the crossing where the accident occurred. However, evidence showed that there were automatic electric signals installed which were functioning properly during the time of accident and had been approved by state authorities as providing reasonable safety measures for such crossings under Nebraska law. The court held that since these warnings met state standards and regulations, they could not be deemed inadequate or insufficient without proof showing otherwise - something which plaintiff failed to do so convincingly. Therefore, no negligence could be attributed to Union Pacific based solely on their compliance with existing safety laws regarding railroad crossings.

In the dissenting opinion for Miller v. Union Pacific R. Co., Justice Cardozo disagreed with the majority's decision to allow a state law that required railroads to compensate employees for injuries sustained on out-of-state trips, even if negligence was not proven. He argued that this violated the Commerce Clause of the U.S Constitution by imposing an undue burden on interstate commerce and creating potential inconsistencies in regulation between states. Furthermore, he contended that it infringed upon federal jurisdiction over railroad operations under the Federal Employers' Liability Act (FELA). In his view, allowing such state laws could lead to unpredictable liability rules across different jurisdictions which would be detrimental for businesses operating across multiple states like railroads.