In Mississippi and Missouri Railroad Company vs. Ward, the Supreme Court of the United States ruled that a railroad company was not liable for damages caused by an employee's negligence in operating a train. The plaintiff had sued the defendant railroad company after his horse was killed when it was struck by one of its trains while crossing a bridge owned by the company. The court held that since there is no contract between an employer and its employees with respect to their duties, any negligence on behalf of such employees does not make them or their employers responsible for damages resulting from such acts. Furthermore, even if there were some contractual obligation between employer and employee regarding performance of duties, this would still be insufficient to hold either party liable because contracts are only binding upon those who enter into them voluntarily; thus, neither party could be held accountable for another’s breach without consenting to do so beforehand. As such, the court found in favor of the defendant railway company and dismissed all claims against it brought forth by Mr. Ward

In Mississippi and Missouri Railroad Company vs. Ward, the dissenting opinion was that a state court had no right to interfere with an action brought by a railroad company in federal court. The majority held that the state courts could not hear cases involving interstate commerce because it would be unconstitutional for them to do so. However, Justice Nelson argued that this decision violated the Tenth Amendment of the Constitution which reserves all powers not delegated to Congress or prohibited by it to the states or people respectively. He further argued that if Congress did have exclusive power over interstate commerce then they should have passed laws explicitly granting such authority instead of relying on judicial interpretation of constitutional provisions. Furthermore, he believed there was nothing in Article III of the Constitution which gave federal courts exclusive jurisdiction over cases involving interstate commerce and thus allowing state courts to adjudicate these matters would not violate any constitutional provision.