In the case of Philadelphia & Reading Coal & Iron Company v. Gilbert, 1917, the U.S. Supreme Court ruled in favor of the defendant, Mr. Gilbert. The plaintiff was a coal company that had leased land from Mr. Gilbert for mining purposes and agreed to pay him royalties based on how much coal they extracted from his property over a certain period of time; however, when it came time to calculate these payments, there was disagreement between both parties about what constituted "coal." The court held that anthracite coal waste or culm (a byproduct produced during mining) should not be included in calculating royalty payments as it did not fall under their lease agreement's definition of "merchantable" or sellable coal - even though this waste could potentially be used for commercial purposes later on after further processing.

In the dissenting opinion for Philadelphia & Reading Coal & Iron Company v. Gilbert, it was argued that the majority's decision to hold employers liable for injuries sustained by employees in their homes due to conditions at work was a significant and unwarranted expansion of employer liability. The dissent contended that this ruling blurred the line between workplace accidents and those occurring outside of work, potentially opening up employers to an endless array of claims related not only to physical injury but also mental distress or other indirect harms resulting from employment conditions. It further suggested that such broad interpretation could lead to unjust outcomes as it would be difficult if not impossible for companies to anticipate all potential risks associated with off-site activities or living situations influenced by working conditions.