In the 1911 case of Robinson v. Baltimore and Ohio Railroad Company, the U.S Supreme Court ruled in favor of the railroad company, dismissing a claim by an African American woman who had been denied equal accommodations on a train due to her race. The plaintiff, Irene Robinson, argued that this was a violation of her rights under both state law and federal civil rights legislation. However, the court held that since she had purchased her ticket in Washington D.C., which did not have laws against racial segregation at that time, there was no breach of contract or discrimination involved when she was asked to move from a 'whites only' car upon entering Maryland where such laws existed. This decision upheld racial segregation policies prevalent during this era.

In the dissenting opinion for Robinson v. Baltimore and Ohio Railroad Company, Justice Holmes disagreed with the majority's decision that held a railroad company liable for injuries sustained by an individual who was trespassing on its property. He argued that it is unreasonable to hold companies responsible for protecting those who are unlawfully present on their properties from potential dangers. According to him, this ruling could set a dangerous precedent where businesses would be forced into costly measures of protection against risks posed by individuals illegally entering their premises. Furthermore, he contended that such liability should only apply if there were explicit knowledge or expectation of trespassers being present at specific locations within the property and not just general awareness of occasional unlawful entry.