The St. Louis, Iron Mountain & Southern Railway Company v. Starbird case in 1916 revolved around a dispute over the liability of damages caused by an accident involving one of the railway company's trains which resulted in the death of Miller, whose estate was represented by Starbird. The Supreme Court ruled that under Arkansas law (where the incident occurred), there is no cause for action against a railroad company for causing death unless it can be proven that such death was due to negligence or misconduct on part of its employees or agents. In this particular case, evidence showed that Miller had been trespassing on private property and his own carelessness contributed significantly to his demise; hence he assumed risk associated with his actions. Therefore, while acknowledging tragic circumstances surrounding Miller’s passing away, court found St.Louis,Iron Mountain & Southern Railway Company not liable as they were not negligent nor did their conduct contribute directly to said fatality.

In the dissenting opinion for St. Louis, Iron Mountain & Southern Railway Company v. Starbird, 1916 case, it was argued that the court majority had erred in its interpretation of a key statute and misapplied precedent to reach their decision. The dissenting justices believed that there were sufficient grounds to hold the railway company liable for Miller's death under federal law because he was engaged in interstate commerce at the time of his fatal accident. They disagreed with the majority's view that Miller’s work did not directly affect interstate commerce and thus fell outside of federal jurisdiction; instead they held that any task performed as part of an ongoing process contributing to interstate trade should be considered within this scope. Furthermore, they contended that previous cases cited by the majority were not applicable since those involved employees who weren't actively working when injured or killed unlike Mr.Miller who died while performing his duties.