In the case of Minneapolis, St. Paul & Sault Ste. Marie Railway Company v. Popplar, Administrator (1914), the U.S Supreme Court was tasked with determining whether a state law that allowed for damages to be awarded without proof of negligence in railway accidents was constitutional under the Fourteenth Amendment's due process clause. The plaintiff argued that his decedent had been killed while working on one of defendant’s trains and sought compensation based on Minnesota statute which held employers liable for injuries sustained by employees during work hours regardless of proven negligence or fault from employer side. The court ruled in favor of the railway company, stating that such laws violated an employer's right to due process as it did not allow them a fair opportunity to defend themselves against claims made by injured workers or their representatives. The ruling emphasized that liability could only be imposed if there is evidence showing negligent behavior leading directly to injury or death.

In the dissenting opinion for the case of Minneapolis, St. Paul & Sault Ste. Marie Railway Company v. Popplar, Administrator (1914), it was argued that the majority's decision to hold a railway company liable for an employee's death due to negligence was incorrect and could set a dangerous precedent. The dissenting justices believed that there wasn't sufficient evidence presented in court proving negligence on part of the railway company leading directly to the worker’s death. They also expressed concern about how this ruling might impact future cases involving workplace accidents, fearing it may unfairly burden companies with liability even when they have taken reasonable precautions against such incidents or where causation is not clearly established.