In the case of St. Joseph and St. Louis Railroad Company v. Humphreys (1891), the U.S Supreme Court ruled in favor of Humphreys, who had sued the railroad company for damages after a train accident caused by negligence on part of the company's employees resulted in his injury. The court held that an employee injured while working has a right to sue their employer if they can prove that their injuries were due to negligence or misconduct from another employee whose rank is high enough to represent the corporation itself, even if there are contractual stipulations stating otherwise between them and their employer. This decision established important precedents regarding employers' liability for workplace accidents and workers' rights to compensation when injured on duty due to no fault of theirs.

The dissenting opinion in the case of St. Joseph and St. Louis Railroad Company v. Humphreys argued that the majority's decision to hold a railroad company liable for damages caused by sparks from its locomotive was unjustified, as it did not take into account whether or not the company had taken reasonable precautions to prevent such an incident from occurring. The dissenting justices believed that liability should only be assigned if negligence could be proven on part of the railroad company, which they felt was not adequately demonstrated in this particular case. They contended that holding companies strictly liable for all damages resulting from their operations would place an undue burden on businesses and stifle economic growth.