In the Southern Railway Co. v. Walter case of 1931, the Supreme Court ruled in favor of Southern Railway Co., reversing a lower court's decision that had awarded damages to an employee injured on the job under Federal Employers' Liability Act (FELA). The plaintiff, Mr. Walter, was a switchman who suffered injuries when he fell from a ladder while trying to climb onto a car during his work shift at night. He claimed that inadequate lighting and unsafe working conditions led to his accident and filed for compensation under FELA which holds railroads liable for employees' injuries caused by negligence. The Supreme Court held that there was insufficient evidence proving negligence on part of Southern Railway Co., stating it wasn't clear whether better lighting would have prevented the accident or if any other specific safety measures were violated by the company leading directly to injury. Therefore, they concluded that liability could not be imposed upon them based solely on speculation or conjecture about what might have contributed towards preventing such accidents without concrete proof.

In the dissenting opinion for Southern Railway Co. v. Walter, Justice Stone argued that the majority's decision was inconsistent with previous rulings and principles of federal jurisdiction. He contended that a state court should not be able to exercise its jurisdiction over an out-of-state defendant based solely on their contractual relationship with an in-state plaintiff, especially when the contract itself had no connection to the forum state. According to him, this would unduly burden interstate commerce and infringe upon due process rights by forcing defendants into potentially inconvenient or unfair litigation environments without sufficient justification. Furthermore, he disagreed with how broadly the majority interpreted "doing business" as a basis for personal jurisdiction over corporations; he believed it should only apply if there is substantial activity within a given state rather than merely incidental or occasional transactions.