The Pennsylvania Railroad Co. v. Chamberlain case in 1932 revolved around the Federal Employers' Liability Act (FELA). The plaintiff, Mrs. Chamberlain, was the administratrix of her husband's estate who had died while working for the Pennsylvania Railroad Company due to a heart attack allegedly caused by overexertion at work. She sought damages under FELA which provides compensation for railroad workers injured on duty due to employer negligence. However, the Supreme Court ruled against Mrs.Chamberlain stating that there wasn't enough evidence proving that her husband’s death resulted from his job duties or any negligence on part of his employer and thus did not meet FELA requirements for compensation.

In the dissenting opinion for Pennsylvania Railroad Co. v. Chamberlain, Justice Stone argued that the majority's decision was inconsistent with previous rulings and misinterpreted federal law regarding employers' liability in workplace accidents. He contended that the court had previously ruled that an employer could be held liable if their negligence played any part, however small, in producing an employee’s injury or death. However, he believed that the majority now required a higher standard of proof from employees to demonstrate causation between employer negligence and injury or death than what was established by Congress under Federal Employers’ Liability Act (FELA). In his view, this shift undermined FELA's purpose: to protect workers by holding companies accountable for unsafe conditions leading to injuries or deaths on-the-job.