In the 1931 case of Spencer Kellogg & Sons, Inc. v. Hicks, Administratrix et al., the U.S Supreme Court ruled in favor of Spencer Kellogg & Sons, a linseed oil manufacturer that had been sued for damages by the family of an employee who died from inhaling toxic fumes at work. The court held that under Louisiana law (where the incident occurred), employers were not liable for injuries or deaths caused by hazardous conditions if those conditions were inherent to and inseparable from the nature of employment itself - as was deemed to be true in this instance with linseed oil manufacturing. This ruling upheld previous decisions made by lower courts and affirmed that workers assumed certain risks when they accepted jobs involving dangerous tasks or environments.

In the dissenting opinion for Spencer Kellogg & Sons, Inc. v. Hicks, Justice Stone argued that the majority's decision to allow a state court to impose liability on an out-of-state corporation was inconsistent with due process rights under the Fourteenth Amendment. He contended that merely shipping goods into a state should not be sufficient grounds for jurisdiction over disputes arising from those goods' use or sale in that state if there is no other connection between the corporation and the state. The imposition of such liability would unfairly burden interstate commerce and discourage corporations from doing business across states lines, he reasoned. Furthermore, he disagreed with the majority's interpretation of International Harvester Co v Kentucky (1914), arguing it did not establish precedent for this case as it involved different circumstances.