In the case of Southern Railway Company v. Clift (1922), the Supreme Court ruled in favor of Southern Railway, reversing a decision by the Georgia Supreme Court. The plaintiff, Mr. Clift, had sued for damages after being injured while working on a railway car that was not equipped with safety appliances mandated by federal law under the Safety Appliance Act. However, it was found that at the time of his injury he was engaged in intrastate commerce rather than interstate commerce - which is what this act regulates - and thus did not fall within its purview. Therefore, despite his injuries resulting from an absence of federally required safety equipment on one of their cars, Southern Railway could not be held liable as they were technically operating within legal boundaries at that specific instance.

In the dissenting opinion for Southern Railway Company v. Clift, Justice Holmes argued that the court should not have overturned the decision of two lower courts without a clear error in judgment. He believed that there was no substantial evidence to suggest any negligence on part of Mr. Clift, and thus it was unjustified to hold him responsible for his own injuries sustained during work at Southern Railway Company's premises. Furthermore, he pointed out that even if there were some degree of contributory negligence by Mr.Clift, under Georgia law this would not bar recovery but only diminish damages proportionately - a point overlooked by majority opinion which held contributory negligence as an absolute defense against liability claims in workplace accidents. In essence, Justice Holmes felt strongly about respecting state laws and decisions made by local courts unless they are clearly erroneous or unconstitutional.