In the 1905 case of San Antonio Traction Company v. Altgelt, the United States Supreme Court ruled in favor of the plaintiff, San Antonio Traction Company. The company had been sued by an individual named Altgelt for injuries he sustained when a streetcar operated by the traction company collided with his carriage. The court found that there was insufficient evidence to prove negligence on part of the traction company or its employees and therefore it could not be held liable for damages. This ruling reinforced legal principles regarding burden of proof in personal injury cases and clarified standards for determining negligence in such situations.

In the dissenting opinion for San Antonio Traction Company v. Altgelt, it was argued that the majority's decision to hold a streetcar company liable for injuries sustained by an individual who had not yet boarded the car was incorrect. The dissent contended that this ruling expanded liability beyond reasonable limits and could potentially lead to frivolous lawsuits against public transportation companies. They maintained that while safety should be paramount in operating such services, there must also be some personal responsibility on part of passengers or potential passengers when navigating around these vehicles. Furthermore, they disagreed with the majority’s interpretation of “duty of care,” arguing instead that duty only arises once a passenger has embarked upon their journey and not before.