In the 1938 case Shields et al. v. Utah Idaho Central Railroad Co., the Supreme Court of the United States ruled in favor of Utah Idaho Central Railroad Co., reversing a decision by lower courts that had awarded damages to Shields and his co-plaintiffs for injuries sustained during an automobile-train collision at a railroad crossing. The plaintiffs argued that they were not given adequate warning about the approaching train, but evidence showed there was sufficient visibility to see an oncoming train from a reasonable distance away. The court held that it is up to drivers to ensure their own safety when approaching railway crossings, even if no explicit warnings are present, as long as conditions allow them enough time and space to stop safely upon seeing an incoming train.

In the dissenting opinion for Shields et al. v. Utah Idaho Central Railroad Co., it was argued that the majority's decision to hold a railroad company liable for injuries sustained by an individual who trespassed onto its property was unjust and set a dangerous precedent. The dissenting justices believed that trespassers should not be entitled to protection or compensation from those whose properties they unlawfully enter, as this would encourage reckless behavior and disregard for private property rights. They also pointed out inconsistencies in the application of legal principles, noting that while courts generally do not protect criminals injured during their illegal activities, they were now protecting a trespasser hurt on railway tracks he had no right to be on. Furthermore, they expressed concern about potential economic implications of such rulings which could lead companies into financial hardship due to increased insurance costs and litigation expenses.