In the Southern Railway Company v. Carson case in 1903, the U.S Supreme Court ruled in favor of Southern Railway Company. The dispute arose when Mr. Carson sued the railway company for damages after he was injured while working as a brakeman due to alleged negligence on part of his fellow employees and lack of safety measures by the employer. However, under Alabama state law at that time, an employee could not sue their employer for injuries caused by fellow workers' negligence unless it was proven that the employer had failed to provide safe work conditions or equipment. The court held that there was no evidence showing any failure from Southern Railway Company's side regarding provision of safe work conditions or equipment which led to Mr.Carson's injury. Therefore, according to Alabama’s “fellow servant rule,” employers were not liable for accidents caused by one employee’s negligence affecting another worker if they have provided a reasonably safe workplace and tools necessary for performing duties safely.

The dissenting opinion in the Southern Railway Company v. Carson case argued that the court majority had erred in its interpretation of the law and facts, leading to an unjust decision. The dissent believed that there was no evidence presented at trial proving negligence on part of Southern Railway Company which led to Mr. Carson's injuries. They contended that Mr. Carson himself was negligent by not taking proper precautions while working near a moving train, thus contributing significantly to his own injury. Furthermore, they disagreed with the majority's view about foreseeability of harm from railway operations; arguing instead that it is unreasonable for a company to predict every possible accident scenario during routine operations and take preventive measures accordingly.