In the Pennsylvania Railroad Co. v. O'Rourke case in 1952, the U.S Supreme Court ruled on a dispute involving an employee's compensation claim under the Federal Employers' Liability Act (FELA). The plaintiff, O’Rourke, was injured while working for Pennsylvania Railroad Company and sought damages based on negligence of his employer under FELA. However, he had already received benefits from his employer through a voluntary relief department funded by both employees and employers to provide aid in cases of sickness or injury. The court held that payments made to an injured worker from such a fund did not relieve the railroad company from liability for further damages if found negligent under FELA. This decision emphasized that contributions made by workers into these funds were their own property and could not be used as offsets against any potential damage awards.

In the dissenting opinion for Pennsylvania Railroad Co. v. O'Rourke, Justice Frankfurter disagreed with the majority's decision to hold the railroad company liable for injuries suffered by an employee who was intoxicated while on duty. He argued that this interpretation of the Federal Employers' Liability Act (FELA) went beyond what Congress intended when it passed the law in 1908 and amended it in 1939. According to him, FELA was designed to protect workers from employer negligence, not their own reckless behavior or misconduct such as intoxication at work which is a clear violation of safety rules set forth by employers themselves. The justice contended that allowing employees to recover damages under these circumstances would undermine workplace discipline and encourage irresponsible conduct among workers which could potentially lead to more accidents and injuries rather than preventing them.