In the case of Pierce v. Tennessee Coal, Iron and Railroad Company in 1898, the U.S. Supreme Court ruled on a dispute involving an injured employee seeking compensation from his employer under Alabama's Employer Liability Act. The plaintiff, Mr. Pierce, was injured while working for the defendant company when he fell through a hole that had been left uncovered by another worker at night without any warning signs or barriers around it. He sued for damages alleging negligence on part of his employer. The court held that under Alabama law, employers were not liable for injuries sustained by their employees due to risks associated with their employment unless there was evidence of willful misconduct or gross negligence which led directly to injury; ordinary negligence wasn't enough to hold them accountable. However, they also noted that if an employee is exposed to unnecessary danger due to carelessness or neglect in providing safe conditions - even if such dangers are inherent in work - then employers could be held responsible. Ultimately though, this decision favored Tennessee Coal as it found no evidence suggesting gross negligence nor did it find proof showing that Pierce’s accident resulted from unnecessary risk created by the company's carelessness or neglect.

In the dissenting opinion for Pierce v. Tennessee Coal, Iron and Railroad Company, Justice Harlan disagreed with the majority's interpretation of the Employers' Liability Act. He argued that it was not Congress' intention to limit liability only to cases where negligence could be directly attributed to an officer or superintendent. Instead, he believed that any employee who had been delegated duties by a superior should also fall under this category. Furthermore, he contended that if a company gives authority over safety measures to an employee and they fail in their duty resulting in injury or death of another worker then such companies should be held liable as per the act’s provisions. The justice felt strongly about protecting workers from hazardous conditions created by negligent coworkers whom they have no control over.