The U.S. Supreme Court case New York, New Haven & Hartford Railroad Co. v. Henagan in 1960 revolved around the issue of whether a railroad company could be held liable for injuries sustained by an employee while off duty but still on the premises of the employer's property due to his work requirements. The plaintiff, Henagan, was injured when he slipped and fell on ice while walking from his sleeping quarters to a restaurant across a public street for dinner during his rest period between shifts at the defendant’s railyard where he worked as a brakeman-conductor. He sued under Federal Employers' Liability Act (FELA). The court ruled that since Henagan was required by employment conditions to stay near or at his workplace during rest periods and thus exposed himself to risks associated with those locations, liability could be imposed upon employers if negligence is proven in maintaining safe conditions within these areas.

In the dissenting opinion for New York, New Haven & Hartford Railroad Co. v. Henagan, it was argued that the majority's decision to hold a railroad company liable for injuries sustained by an employee due to negligence of fellow employees contradicted previous rulings and interpretations of the Federal Employers' Liability Act (FELA). The dissenting justices believed that this ruling expanded liability under FELA beyond what Congress intended when they passed the law in 1908. They pointed out that traditionally, employers were not held responsible for accidents caused by their employees unless there was evidence of negligence on part of management or failure to provide safe working conditions. In this case, however, no such evidence existed; instead it seemed like a simple accident between two workers which should have been handled as per state laws rather than federal ones. This expansion could potentially lead to unjust outcomes and financial burdens on companies who are now being held accountable for actions outside their control.