In the 1940 case Moore v. Illinois Central Railroad Co., the U.S. Supreme Court ruled in favor of the plaintiff, a railroad worker who had been injured on the job and sought compensation under federal law. The court found that although his injury occurred while he was performing routine maintenance work, it still fell within "the course of employment" as defined by federal statute because it happened during working hours at a place where he might reasonably be expected to be in carrying out his duties. This decision clarified that for purposes of workers' compensation claims under federal law, an employee's injury need not result from some unusual or unexpected event; rather, if it occurs during normal work activities at a time and place associated with those activities, then it is compensable.

The dissenting opinion in the case of Moore v. Illinois Central Railroad Co., argued that the majority's decision was inconsistent with previous rulings and principles of law. The dissent contended that a railroad company should not be held liable for damages caused by an employee who acted outside the scope of his employment, especially when such actions were criminal and against company policy. They believed this interpretation would unfairly penalize employers for acts they could not reasonably foresee or control, thereby creating an undue burden on businesses. Furthermore, it was suggested that holding companies responsible for their employees' illegal activities might discourage them from hiring individuals who had been rehabilitated after past criminal behavior due to fear of potential liability.