In the 1931 case of New York, New Haven & Hartford Railroad Co. v. Bezue, the U.S Supreme Court ruled in favor of the railroad company against a claim made by Bezue for damages due to negligence on part of the railroad company. The plaintiff was injured while working as an employee for a contractor hired by the defendant and sued under Federal Employers' Liability Act (FELA). However, it was determined that FELA did not apply because Bezue wasn't directly employed by any interstate rail carrier but rather worked for an independent contractor who had been contracted to perform work on behalf of such carriers. Therefore, he could not be considered as being "employed" under FELA's terms and conditions which specifically cover employees involved in interstate commerce activities only.

In the dissenting opinion for New York, New Haven & Hartford Railroad Co. v. Bezue, Justice Stone argued that the majority's decision to uphold a Connecticut statute allowing recovery of damages from railroads in cases where employees were injured due to negligence was inconsistent with previous rulings and federal law. He contended that this ruling would unfairly penalize railroad companies by holding them responsible for accidents beyond their control or foresight. Furthermore, he believed it violated principles of fairness as it imposed liability without fault on employers while exempting other parties who might also be at fault from any responsibility. The justice expressed concern about the potential negative impact on interstate commerce and warned against state laws interfering with national uniformity in matters related to railway operation safety standards.