In the case of Southern Railway Co. et al. v. Dantzler, Administratrix, 1931, the Supreme Court ruled in favor of Southern Railway Company and its co-defendants against a claim brought by Mrs. Dantzler as administratrix for her deceased husband's estate. Mr. Dantzler was killed while working on a railway line owned by one of the defendants when he came into contact with an uninsulated wire carrying high voltage electricity which had been negligently left hanging low over the tracks after repair work had been done on it earlier that day by another defendant company's employees who were contracted to maintain these wires for telegraph services along this rail route. The court held that under South Carolina law (where this incident occurred), there was no duty owed to Mr.Dantzler from either his employer or any other party involved because he should have known about potential dangers associated with such wires due to his experience as a railroad worker and thus assumed risk inherent in his job role; therefore they could not be held liable for negligence leading to his death.

In the dissenting opinion for Southern Railway Co. et al. v. Dantzler, 1931, Justice Stone argued that the majority's decision to uphold a state law allowing recovery of damages in wrongful death cases was inconsistent with previous rulings by the Court and violated principles of federalism. He contended that under existing precedent, states could not impose liability on interstate carriers for accidents occurring outside their borders without violating due process rights guaranteed by the Fourteenth Amendment. In his view, this case represented an unwarranted expansion of state power at the expense of federal authority over interstate commerce and constitutional protections against arbitrary government action.