In the 1948 case Reynolds v. Atlantic Coast Line Railroad Co., the U.S Supreme Court was asked to determine whether a railroad company could be held liable for injuries sustained by an employee, even if those injuries were not directly caused by negligence on part of the employer. The plaintiff, Mrs. Reynolds, argued that her husband's death from pneumonia was due to his exposure to inclement weather while working for the defendant and thus they should be held responsible under Federal Employers' Liability Act (FELA). However, it was found that Mr. Reynolds had been adequately provided with protective clothing and equipment by his employer which he chose not to use properly or at all times during work hours in bad weather conditions leading up to his illness and subsequent death. Therefore, there wasn't any evidence of negligence on part of Atlantic Coast Line Railroad Company contributing towards this unfortunate incident as per FELA requirements for liability claims against employers involving their employees' safety at workplace environments. Hence, ruling favored defendant absolving them from any responsibility regarding Mr.Reynolds' demise.

In the dissenting opinion for Reynolds v. Atlantic Coast Line Railroad Co., Justice Robert H. Jackson disagreed with the majority's decision to uphold a Florida state law that allowed family members of deceased individuals to sue for damages resulting from wrongful death, even if they were not financially dependent on the decedent. He argued that this law was inconsistent with federal laws governing interstate commerce and thus should be invalidated under the Supremacy Clause of the U.S Constitution. According to Justice Jackson, allowing such lawsuits could potentially expose railroad companies and other businesses involved in interstate commerce to excessive liability, which would ultimately harm their ability to operate efficiently across state lines. Furthermore, he contended that it is unfair for these companies to have different legal obligations depending on where an accident occurs since they are engaged in nationwide operations.