In the case of Robinson v. Baltimore and Ohio Railroad Company, 1914, the U.S Supreme Court ruled in favor of the defendant, Baltimore and Ohio Railroad Company. The plaintiff, a black woman named Ida Robinson who was traveling from Washington D.C to Philadelphia on one of their trains had sued for racial discrimination after she was asked by a conductor to move from her first-class seat to another car because white passengers objected to her presence. She refused and was forcibly removed from her seat by two policemen at the next stop. However, upon reviewing evidence presented during trial proceedings which included testimony that there were no "Jim Crow" laws requiring segregation on interstate carriers in either Maryland or Pennsylvania at that time nor any policy enforced by B&O railroad company itself regarding such matter; it became clear that this incident resulted not due to systemic racism but rather an individual act committed by its employee(s). Henceforth ruling out any liability towards them under federal law as they could not be held responsible for actions taken without their knowledge or consent.

The dissenting opinion in the case of Robinson v. Baltimore and Ohio Railroad Company argued that the majority's decision was a misinterpretation of the Federal Employers' Liability Act (FELA). The dissent contended that FELA should be interpreted to hold employers liable for injuries sustained by their employees during work, regardless of whether or not negligence could be proven on part of the employer. They believed this interpretation would better align with Congress’s intent when passing FELA - to protect railroad workers from dangerous working conditions and provide them with compensation if injured while performing their duties. Therefore, they disagreed with the majority's ruling which required proof of negligence on behalf of B&O Railroad Company before awarding damages to Mr. Robinson.