The Southern Railway-Carolina Division v. Bennett, Administratrix case in 1913 revolved around a dispute over liability for the death of an employee. The plaintiff, Mrs. Bennett, sued the railway company for negligence after her husband was killed while working on one of its trains in South Carolina. She claimed that his death resulted from the company's failure to provide safe equipment and conditions as required by federal law under the Safety Appliance Act (SAA). However, the Supreme Court ruled against her claim stating that SAA did not apply because Mr. Bennett's duties were intrastate rather than interstate commerce at time of accident; thus it fell outside federal jurisdiction and within state laws which had different standards for employer liability.

In the dissenting opinion for Southern Railway-Carolina Division v. Bennett, Justice Holmes disagreed with the majority's ruling that allowed a state to regulate interstate commerce in ways that could potentially conflict with federal law. He argued that such an interpretation of states' rights would lead to chaos and confusion as each state could enact its own regulations on interstate commerce, leading to inconsistencies and potential conflicts between different jurisdictions. Furthermore, he contended that allowing states this level of control over interstate commerce was contrary to the intent of the framers who sought a unified national economy under federal regulation. Therefore, he believed it was necessary for Congress or other federal authorities rather than individual states to have ultimate authority over matters related to interstate trade and transportation.