In the case of North Carolina Railroad Company v. Lee, 1922, the Supreme Court ruled in favor of the railroad company. The lawsuit was initiated by Mrs. Lee who sued for damages after her husband's death due to a train accident while he was working as a section hand on the railroad line. The court held that under North Carolina law, an employer is not liable for injuries caused by fellow employees' negligence unless it can be proven that they were acting outside their scope of employment or if there was contributory negligence from the victim himself which led to his injury or death. In this case, Mr.Lee had been standing too close to another track when he got hit by a passing train and hence it could not be established beyond doubt that his co-workers were solely responsible for his demise.

In the dissenting opinion for North Carolina Railroad Company v. Lee, it was argued that the majority's decision to uphold a state law allowing damages against railroads for employee deaths caused by negligence was inconsistent with federal laws regulating interstate commerce. The dissenting justices believed that such matters should be governed by uniform national standards rather than varying state laws. They contended that this inconsistency could lead to confusion and unfairness in how railroad companies are held accountable across different states. Furthermore, they expressed concern about potential negative impacts on the economy due to increased liability risks for railroads involved in interstate commerce.