The U.S. Supreme Court case Minneapolis, St. Paul & Sault Ste. Marie Ry Co v Moquin in 1930 revolved around the issue of whether a railroad company could be held liable for injuries sustained by an employee while off duty but still on the premises of his employer's property. The plaintiff, Moquin, was injured when he fell into a pit near his sleeping quarters provided by the railway company after finishing his shift as a section hand and watchman at one of its stations in North Dakota. He sued under the Federal Employers' Liability Act (FELA), which allows employees to recover damages from their employers for injuries suffered during employment due to negligence. The court ruled that although FELA does not cover all accidents occurring on an employer’s premises, it did apply in this case because there was sufficient connection between Moquin's work and where/how he got injured - even though he wasn't technically working at that moment - making it reasonable to hold the railway company responsible for maintaining safe conditions throughout its property.

In the dissenting opinion for Minneapolis, St. Paul & Sault Ste. Marie Ry. Co v Moquin, Justice Stone argued that the majority's decision was inconsistent with previous rulings of the court and violated principles of federalism by allowing a state to regulate interstate commerce indirectly through its workers' compensation laws. He contended that Minnesota's law should not apply because it interfered with interstate commerce by imposing additional costs on railroads operating across state lines, which is contrary to Congress’s intent in passing the Federal Employers Liability Act (FELA). According to Justice Stone, FELA aimed at creating uniformity in liability rules for railroad companies involved in interstate business rather than subjecting them to different standards set by individual states.