In the case of Schlemmer v. Buffalo, Rochester and Pittsburgh Railway Company in 1906, the U.S Supreme Court ruled on a dispute involving an employee's injury at work. The plaintiff, Mr. Schlemmer was injured while working for the defendant railway company when he fell into a pit that was not properly lit or marked as dangerous. He sued his employer under federal law which required employers to provide safe workplaces for their employees. However, the lower court dismissed his claim stating that it lacked jurisdiction because Pennsylvania state law did not recognize such claims by employees against their employers due to contributory negligence (the idea that if an employee contributed in any way to their own injury they could not sue). On appeal, however, the Supreme Court reversed this decision arguing that federal safety laws superseded state laws in these matters and remanded back down for further proceedings consistent with its opinion.

In the dissenting opinion for Schlemmer v. Buffalo, Rochester and Pittsburg Railway Company, it was argued that the court majority had erred in their interpretation of the Federal Safety Appliance Act. The dissenting justices believed that Congress intended to impose absolute liability on employers for injuries sustained by employees due to defective equipment, regardless of whether or not negligence could be proven. They contended that this strict liability was necessary to protect workers from dangerous conditions often beyond their control in an inherently risky industry. Therefore, they disagreed with the majority's decision which required proof of negligence on part of employer before compensation could be awarded under this act.