In the 1917 case of Nelson v. Southern Railway Company, the United States Supreme Court ruled in favor of the defendant, Southern Railway Company. The plaintiff, Mr. Nelson was a railway worker who had been injured on duty and sued his employer for negligence under the Federal Employers' Liability Act (FELA). However, he failed to provide sufficient evidence to prove that his injuries were due to negligence by his employer or fellow employees as required by FELA. Therefore, despite acknowledging that an injury occurred while performing work duties does not automatically imply liability on part of the company unless clear proof is provided showing violation of safety norms or negligent behavior leading directly to said injury.

In the dissenting opinion for Nelson v. Southern Railway Company, the justice argued that the majority's decision to hold a railway company liable for injuries sustained by an employee while on duty was incorrect. The justice contended that under federal law, employers should not be held responsible unless they were directly at fault or negligent in some way. In this case, there was no evidence of negligence on part of the employer and thus it was unjust to impose liability solely based on employment status. Furthermore, he believed that such rulings could have detrimental effects on businesses as they would constantly be exposed to potential lawsuits without any wrongdoing or neglect from their side. He also expressed concern about how this ruling might set a dangerous precedent where companies are forced into bankruptcy due to excessive litigation costs even when they are not at fault.