In the case of Seaboard Air Line Railway v. Horton (1913), the U.S Supreme Court ruled in favor of Seaboard Air Line Railway, reversing a decision made by the Supreme Court of Georgia. The dispute arose when Horton was injured while working for the railway company and sought compensation under Georgia's Employer’s Liability Act. However, his employment contract stipulated that any injury claims would be handled according to Virginia law - where he had been hired - which did not allow such suits unless negligence could be proven. The court held that since both parties agreed to this provision freely and without fraud or duress, it should be upheld even though it limited Horton's rights under Georgia law. This ruling affirmed an employer's right to limit liability through contractual agreements with employees.

In the dissenting opinion for Seaboard Air Line Railway v. Horton, Justice Holmes disagreed with the majority's decision to uphold a Georgia law that allowed an injured employee to sue their employer in any county where the injury occurred. He argued that this law was unconstitutional because it violated due process rights by potentially subjecting defendants to lawsuits in counties far from their place of residence or business operations, which could impose undue hardship and inconvenience on them. Furthermore, he contended that such laws unfairly favored plaintiffs by giving them too much discretion over where they could file suit. In his view, these factors combined created an unjust imbalance between plaintiffs and defendants' rights within the legal system.