In the 1913 case of Missouri, Kansas & Texas Railway Company v. West, the U.S Supreme Court dealt with a dispute over land ownership rights between a railway company and an individual named West. The railway company claimed that it had acquired certain lands under an Act of Congress in 1875 which granted them to railroad companies for construction purposes. However, before the grant was made effective by completion of their line through these lands in question, they were occupied by settlers including Mr. West who purchased them from other settlers or directly from government itself after settlement and improvement as per existing laws at that time. The court ruled against the railway company stating that its claim to these lands did not arise until it completed its line through those areas; hence any settler's claims prior to this would take precedence according to law governing disposal of public domain (land). Therefore, Mr.West’s title was upheld since he had settled on and improved his parcel before completion date set out in said act granting such lands to railroads.

In the dissenting opinion for Missouri, Kansas & Texas Railway Company v. West (1913), Justice Holmes disagreed with the majority's ruling that a railway company could be held liable for injuries sustained by an employee who was not given sufficient training or instruction. He argued that it is unreasonable to expect employers to anticipate every possible scenario and provide specific instructions accordingly. Instead, he believed that employees should exercise common sense in their duties and take responsibility for their own safety when faced with unexpected situations. Furthermore, he contended that if an employer were required to instruct its employees on every conceivable risk they might encounter while performing their jobs, this would place an undue burden on businesses and potentially stifle economic growth.