In the 1952 case of New York, New Haven & Hartford Railroad Co. v. Nothnagle et al., the U.S Supreme Court ruled in favor of the railroad company, reversing a previous decision by a lower court that had awarded damages to Mr. and Mrs. Nothnagle for injuries they sustained during a train derailment caused by an act of sabotage on the tracks. The Supreme Court held that under federal law, specifically Section 7 of Federal Employers' Liability Act (FELA), railroads are not liable for damages resulting from acts outside their control such as sabotage unless negligence can be proven on their part in failing to prevent it or respond adequately after its occurrence. This ruling established important precedent regarding liability standards for railroads under FELA.

In the dissenting opinion for New York, New Haven & Hartford Railroad Co. v. Nothnagle et al., Justice Robert H. Jackson disagreed with the majority's decision to uphold a Connecticut law that allowed injured passengers to sue railroads without proving negligence on their part. He argued that this ruling violated the railroad company's due process rights under the Fourteenth Amendment of the U.S Constitution by imposing liability without fault and was inconsistent with previous Supreme Court decisions which required proof of negligence in personal injury cases involving common carriers like railroads or airlines. Furthermore, he contended that such laws could potentially lead to unjust outcomes as they did not take into account circumstances where accidents were unavoidable or caused by factors beyond control of these companies.