In the case of Seaboard Air Line Railway v. Kenney, Administrator of Capehart, alias Eason (1915), the U.S. Supreme Court ruled in favor of the plaintiff, Kenney who was representing Capehart's estate. The case involved a fatal accident where Capehart was killed by a train owned and operated by Seaboard Air Line Railway while he was walking along its tracks at night. The railway company argued that it wasn't liable for damages as Capehart had trespassed on their property and they owed no duty to him beyond not injuring him willfully or wantonly. However, based on evidence presented during trial showing negligence on part of the railway company such as failure to ring bell or blow whistle when approaching known pedestrian crossings which could have prevented this accident from happening; court held that even though trespassers are generally not entitled to same level protection as invitees or licensees under common law principles but still railroad companies owe them certain degree care especially in places where people are known cross frequently despite being private property thus making them foreseeable victims hence reversing lower court's decision dismissing lawsuit against defendant thereby allowing plaintiff's claim proceed further towards possible settlement or jury trial.

In the dissenting opinion for Seaboard Air Line Railway v. Kenney, it was argued that the court majority erred in its interpretation of the Federal Employers' Liability Act (FELA). The dissenting justices believed that FELA should be interpreted to allow recovery for injuries caused by any negligence on part of a railway company's employees, not just those specifically engaged in interstate commerce at the time of an accident. They contended that such a narrow reading contradicted Congress's intent when passing FELA and undermined its purpose: to protect railroad workers from harm due to their employers' negligence. Furthermore, they disagreed with the majority’s view about whether or not Capehart was involved in interstate commerce at his time of death; they held he was indeed involved as he had been ordered back into service after completing an interstate trip and thus remained under obligation to his employer.