In the 1945 case of Poff, Executrix v. Pennsylvania Railroad Co., the United States Supreme Court addressed a dispute over liability for a fatal accident involving an employee of the railroad company. The plaintiff, Poff, was representing her deceased husband's estate and argued that his death was due to negligence on part of his employer - Pennsylvania Railroad Company. However, the court ruled in favor of the defendant (the railroad company), stating that there wasn't sufficient evidence to prove negligence or violation of Federal Employers' Liability Act by them. This decision upheld earlier rulings from lower courts which had also found in favor of Pennsylvania Railroad Company.

In the dissenting opinion for Poff v. Pennsylvania Railroad Co., the justice argued that there was a lack of substantial evidence to support the jury's verdict in favor of Mrs. Poff, who claimed her husband died due to negligence by his employer, Pennsylvania Railroad Company. The justice believed that Mr. Poff's death could not be definitively linked to any negligent act on part of his employer and thus it was incorrect for them to bear responsibility for compensation under Federal Employers' Liability Act (FELA). He further stated that FELA should not be interpreted so broadly as to hold employers liable without clear proof of negligence directly causing harm or death, which he felt wasn't present in this case.