In the case of New York Central and Hudson River Railroad Company v. Car, 1914, the U.S. Supreme Court was tasked with determining whether a railroad company could be held liable for injuries sustained by an employee due to negligence on part of another employee. The plaintiff, Mr. Car, was injured while working as a brakeman when he fell from his train car because it had been negligently coupled by another worker employed by the same company. The court ruled in favor of Mr.Car stating that under Federal Employers' Liability Act (FELA), employers are responsible for maintaining safe work environments and can be held accountable if their failure to do so results in injury or death to employees even if caused by fellow workers' negligence.

In the dissenting opinion for New York Central and Hudson River Railroad Company v. Car, Justice Holmes disagreed with the majority's interpretation of liability under the Federal Employers' Liability Act (FELA). He argued that FELA was not intended to impose strict liability on employers for all injuries sustained by employees during their employment. Instead, he believed it only applied when an employer's negligence contributed to an employee's injury. In this case, a railroad worker died after falling from a train car while performing his duties in icy conditions; however, there was no evidence of negligence on part of the company as they had provided handholds and footholds which were standard safety measures at that time. Therefore, according to Justice Holmes’ view, since there wasn't any proven negligent act or omission by the employer contributing directly or indirectly to the accident causing death of its employee - even though it occurred during course of employment - should not result in imposition of liability upon them under FELA.