In the case of New York Central Railroad Company v. Ambrose, Administratrix (1929), the United States Supreme Court ruled on a dispute involving an employee's death due to negligence by his employer. The deceased was employed as a switchman and while performing his duties, he fell from a ladder attached to a car that was in poor condition. His widow filed suit against the railroad company under the Federal Employers' Liability Act (FELA). The jury found for Mrs. Ambrose and awarded her damages; however, this decision was reversed by an appellate court which held that there wasn't sufficient evidence of negligence on part of the railroad company. The Supreme Court disagreed with this reversal stating that it is up to juries - not judges - to decide whether or not there has been negligence based upon presented facts and circumstances surrounding each individual case. Therefore, they reinstated Mrs.Ambrose’s award because she had provided enough evidence for reasonable minds could differ about whether or not there had been negligent maintenance leading to unsafe working conditions causing her husband's fatal accident.

In the dissenting opinion for New York Central Railroad Company v. Ambrose, the justice argued that the majority's decision was inconsistent with previous rulings and misinterpreted key aspects of federal law. The justice contended that under the Federal Employers' Liability Act (FELA), a railroad company could be held liable for injuries to its employees caused by negligence, even if such negligence was not directly attributable to any specific individual within the company. He disagreed with the majority's view that liability should only apply when an act of negligence can be traced back to a particular person in charge or control of operations at fault. Instead, he asserted that FELA intended to hold corporations accountable as entities capable of negligent action themselves through their collective conduct and decisions made on behalf of them by their agents or representatives.