In the case of Southern Railway Company v. Samuel E. Greene, 1909, the U.S Supreme Court was tasked with determining whether a railway company could be held liable for injuries sustained by an employee while on duty in another state where the injury occurred due to negligence from fellow employees and not directly from employer's negligence. The plaintiff, Greene, was injured in South Carolina but sought compensation under Georgia law which allowed recovery for such injuries even if they were caused by co-workers' carelessness rather than direct employer negligence - something that South Carolina law did not permit at that time. The court ruled in favor of Southern Railway Company stating that since the contract of employment was made in South Carolina and because it contained no provision stipulating adherence to Georgia laws regarding workplace accidents or liability thereof; therefore, only South Carolina’s laws applied here. This decision reinforced principles of federalism and states’ rights over their own legal systems.

In the dissenting opinion for Southern Railway Company v. Samuel E. Greene, Justice Holmes disagreed with the majority's decision that a railway company could be held liable for injuries sustained by an employee due to negligence of fellow employees under Alabama law. He argued that this interpretation was inconsistent with common law principles and previous court decisions which generally exempted employers from such liability unless they were directly negligent or had knowledge of unsafe conditions. Furthermore, he contended that it was not reasonable to hold companies responsible for all actions of their employees as it would place an undue burden on them and potentially harm economic productivity. Lastly, he expressed concern about judicial overreach in interpreting state laws in ways not intended by state legislatures.