The St. Louis & San Francisco Railroad Company v. Conarty, Administratrix case in 1914 revolved around a dispute over the death of an employee who was killed while working on the railroad tracks. The deceased's wife sought damages from the company for negligence under Oklahoma law which allowed recovery if there was any degree of negligence by the employer contributing to injury or death, even if it wasn't entirely their fault (contributory negligence). However, since this incident occurred on interstate commerce lines, federal laws applied instead and they required proof that employer’s negligence was solely responsible for such incidents (fellow-servant rule). The Supreme Court ruled in favor of the railroad company stating that state law could not supersede federal regulations regarding interstate commerce matters. Therefore, Mrs. Conarty failed to establish her claim as she couldn’t prove sole responsibility of her husband’s employers towards his fatal accident.

In the dissenting opinion for St. Louis & San Francisco Railroad Company v. Conarty, it was argued that the majority's decision to hold the railroad company liable for damages resulting from a fire caused by sparks emitted from its locomotive was unjustified and inconsistent with established legal principles. The dissenting justices contended that there was insufficient evidence to prove negligence on part of the railroad company or causation between its actions and the damage suffered by Mrs. Conarty’s property due to fire outbreak. They also pointed out that previous court decisions had ruled in favor of defendants in similar cases where plaintiffs were unable to provide concrete proof of negligence or direct causation, suggesting an inconsistency in how such cases are adjudicated.