In the case of Schreiber v. Burlington Northern, Inc., et al., 1984, the U.S Supreme Court ruled in favor of Burlington Northern Railroad Company (BN). The plaintiff, Robert Schreiber had sued BN for injuries he sustained while working as a brakeman and switchman for them. He claimed that his injuries were due to negligence on part of BN under Federal Employers' Liability Act (FELA). However, it was found that at the time of injury he was not engaged in interstate commerce which is a requirement under FELA to establish liability. Therefore, his claim did not fall within its purview. The court held that an employee's duties must be directly related to or substantially affect interstate commerce for FELA coverage and since Schreiber’s work did not meet this criteria at the time of injury; hence BN could not be held liable.

In the dissenting opinion for Schreiber v. Burlington Northern, Inc., Justice Brennan disagreed with the majority's interpretation of the Federal Employers' Liability Act (FELA). He argued that FELA was intended to be liberally construed in favor of injured workers and that this broad construction should extend to defining "accident." The majority held that an accident did not occur unless there was a sudden event or unusual strain; however, Brennan believed this definition too narrow. Instead, he suggested any unexpected injury occurring during work could qualify as an accident under FELA. Furthermore, he criticized the majority's reliance on British common law cases which were decided before FELA’s enactment and thus irrelevant to its interpretation. Lastly, Brennan expressed concern about how this decision would affect future claims by railroad workers who suffer injuries over time due to their working conditions rather than from a single traumatic event.