The Pittsburg and Southern Coal Company v. Bates case in 1894 revolved around a dispute over land ownership rights between the coal company and an individual named Bates. The Supreme Court ruled in favor of Bates, upholding his claim to the contested property. The court found that there was no evidence to support the coal company's assertion that they had acquired ownership through adverse possession - a doctrine allowing someone to obtain another person's real property without compensation if certain conditions are met, such as open occupation for a statutory period (usually several years). In this case, it was determined that although the coal company had been mining on part of the disputed land for many years, their activities did not meet all necessary criteria for claiming adverse possession because they were not sufficiently open or notorious.

In the dissenting opinion for Pittsburg and Southern Coal Company v. Bates, the justice argued that the majority's decision was based on a misinterpretation of both fact and law. The justice believed that there was no evidence to support the claimant's assertion that he had been injured due to negligence by his employer, as required under Pennsylvania state law at the time. Furthermore, they disagreed with how broadly the majority interpreted this law in order to find in favor of Bates. They contended that such an interpretation could potentially open up employers to liability for any injury suffered by their employees while on duty, regardless of whether or not it was directly caused by their actions or lack thereof - a situation which they felt would be unfair and contrary to established legal principles regarding employer liability.