In the case of New England Railroad Company v. Conroy, 1899, the U.S Supreme Court ruled in favor of the railroad company. The plaintiff, Conroy had sued for damages after a collision between his horse-drawn wagon and one of the defendant's trains at a railway crossing resulted in injuries to him and death to his horses. However, it was found that he did not exercise due care while approaching and crossing over such an obviously dangerous place as a railway track where trains are constantly passing at high speed. It was held that if by looking up or down the tracks before attempting to cross them he could have seen an approaching train in time to avoid it but failed to do so then he is guilty of contributory negligence which bars recovery under Rhode Island law applicable here even though there may also be negligence on part of employees operating said train.

In the dissenting opinion for New England Railroad Company v. Conroy, the justice disagreed with the majority's ruling that allowed a railroad worker to sue his employer under state law for injuries sustained on the job. The justice argued that federal law should govern such cases because railroads are engaged in interstate commerce and thus fall under federal jurisdiction. He contended that allowing states to regulate these matters would lead to inconsistent rulings across different jurisdictions, which could disrupt and complicate railway operations nationwide. Furthermore, he believed this decision undermined Congress' authority over interstate commerce as granted by the Constitution. Therefore, he concluded that it was inappropriate for state laws to apply in this case.