In the 1910 case of Mobile, Jackson & Kansas City Railroad Company v. Turnipseed, Administrator, the U.S. Supreme Court ruled in favor of the railroad company and reversed a judgment from a lower court that had awarded damages to an individual who was injured while working on one of its trains. The plaintiff argued that he was not provided with safe equipment for his work as required by federal law under the Safety Appliance Act (SAA). However, upon review, it was determined that at the time of injury he wasn't engaged in interstate commerce which is necessary for SAA protections to apply. Therefore, since his activities did not fall within this scope when he got hurt; hence they were considered intrastate rather than interstate commerce and thus outside federal jurisdiction according to existing laws at that time.

In the dissenting opinion for Mobile, Jackson & Kansas City Railroad Company v. Turnipseed, it was argued that the court majority had erred in its interpretation of Mississippi law and its application to this case. The dissent contended that under Mississippi law, a railroad company is not liable for damages caused by sparks from locomotives unless negligence can be proven. In this case, there was no evidence presented to prove such negligence on part of the railroad company. Therefore, according to the dissenting justices' view, it was incorrect for the court majority to uphold a verdict against the railroad company based solely on an assumption of liability without proof of negligence or fault.