In the case of Minneapolis and St. Louis Railway Company v. Gardner, 1899, the U.S Supreme Court ruled in favor of the railway company. The dispute arose when a train owned by the railroad company collided with a wagon driven by Gardner at an unguarded crossing resulting in injuries to Gardner's wife who was also present in the wagon. The lower court had awarded damages to Mr.Gardner for his personal injuries but denied any compensation for his wife's injuries on grounds that she could file her own suit if she wished so. On appeal, it was argued that under Iowa law (where incident occurred), husband has right to recover damages for loss of services due to injury caused to his wife through negligence of another party and hence he should be compensated for same as well. However, this argument was rejected by Supreme Court stating that such laws were not applicable here because Mrs.Gardner herself did not sue or join her husband’s lawsuit against railway company nor there is any evidence showing loss suffered specifically due him losing services provided by his injured spouse.

In the dissenting opinion for Minneapolis and St. Louis Railway Company v. Gardner, it was argued that the court majority erred in its interpretation of liability under federal law. The dissent contended that a railway company should not be held liable for injuries sustained by an employee who knowingly accepted risks associated with their job duties, such as working on moving trains or around heavy machinery. This view maintained that employees are aware of potential dangers when they accept employment and therefore voluntarily assume these risks as part of their contractual agreement with the employer. Therefore, according to this perspective, holding companies responsible for accidents occurring during normal work operations would unjustly burden them with excessive liabilities and potentially discourage economic activity.