In the 1924 case of New York Central Railroad Company v. Chisholm, Administrator, the U.S Supreme Court ruled in favor of the railroad company. The case involved a dispute over liability for an accident that resulted in death. The deceased was employed by a contractor hired by New York Central to repair its tracks and was killed while performing his duties when he was struck by one of the company's trains. His estate sued for damages under federal employers' liability laws but lost at trial court level as it found that those laws did not apply because he wasn't directly employed by the railroad company. The decision was appealed and reached all way up to Supreme Court which upheld lower court’s ruling stating that since deceased employee worked for an independent contractor rather than being directly on payroll of railway company, federal employer liability law didn’t cover him thus absolving New York Central from any responsibility towards compensation claims made against them.

The dissenting opinion in the case of New York Central Railroad Company v. Chisholm, Administrator argued that the majority's decision to hold a corporation liable for its employee’s actions was unjust and inconsistent with established legal principles. The dissent contended that corporations should not be held responsible for acts committed by employees outside their scope of employment or without express authorization from corporate management. It further asserted that such an expansive view of corporate liability could lead to unfair outcomes and potentially stifle business activity due to fear of litigation risks. This perspective emphasized individual responsibility over collective accountability, suggesting it is more justifiable and practical in terms of law enforcement and economic development.