In the 1916 case of New York Central & Hudson River Railroad Company v. Beaham, the United States Supreme Court addressed a dispute over damages resulting from an accident involving a train and carriage. The plaintiff, Beaham, was injured when his horse-drawn carriage was struck by one of the defendant's trains at a railroad crossing in Ohio. He sued for damages under federal law which required railroads to provide "due care" to prevent accidents at crossings. The lower courts ruled in favor of Beaham but on appeal, the Supreme Court reversed this decision stating that there had been no negligence on part of the railroad company as they had adhered to all safety regulations including blowing whistles and ringing bells prior to reaching crossings as per state laws. Furthermore, it found that Beaham himself had not exercised due caution while approaching and crossing tracks despite being aware of an incoming train.

In the dissenting opinion for the case of New York Central & Hudson River Railroad Company v. Beaham, it was argued that there was no negligence on part of the railroad company and therefore they should not be held liable for damages. The dissenting justices believed that Mr. Beaham had ample opportunity to avoid injury but failed to do so due to his own carelessness or recklessness. They pointed out that he ignored multiple warnings about the approaching train, including a loud whistle and an illuminated headlight visible from a considerable distance away at night time when visibility is low. Furthermore, they contended that Mr. Beaham's decision to cross over two sets of tracks instead of using a nearby footbridge also demonstrated his disregard for safety precautions which ultimately led to his unfortunate accident.