In the 1907 case of Patch v. Wabash Railroad Company, the U.S Supreme Court ruled in favor of Wabash Railroad Company. The plaintiff, Patch, had sued for damages after a train collision resulted in injuries and loss of livestock. He claimed that the railroad company was negligent because it failed to provide a reasonably safe place for him to unload his cattle from their freight cars. However, the court found no negligence on part of the defendant as they had provided standard facilities which were commonly used at all stations and deemed safe by industry standards at that time. Furthermore, there was no evidence presented showing any specific defects or dangers associated with these facilities which could have led to an accident or injury under normal circumstances.

In the dissenting opinion for Patch v. Wabash Railroad Company, it was argued that the majority's decision to uphold a lower court ruling against Patch was incorrect. The dissenting justices believed that there were significant errors in how the trial court had instructed the jury on matters of law related to negligence and liability. They contended that these instructions unfairly prejudiced the case against Patch, who had been injured while working for Wabash Railroad Company and sought compensation from his employer under federal employers' liability laws. In their view, these legal errors should have warranted a reversal of judgment or at least a new trial so as not to deny Patch his right to fair adjudication.