The St. Louis-San Francisco Railway Company v. Mills case in 1925 revolved around the death of a railway employee, Mr. Mills, who was killed while on duty due to an alleged negligence by the company. The widow and administratrix of his estate, Mrs. Mills, sued for damages under the Federal Employers' Liability Act (FELA). The trial court ruled in favor of Mrs. Mills and awarded her $12,000 in damages; however, this decision was reversed by the Supreme Court of Alabama which held that there wasn't sufficient evidence to prove negligence on part of the railway company. Upon appeal to U.S Supreme Court it was decided that although FELA does not make employers absolutely liable for work-related injuries or deaths but only for those caused "in whole or in part" by their negligence - it is up to juries rather than judges to decide whether an employer's conduct constitutes such negligence based on presented evidences during trials. Therefore,the U.S Supreme Court overturned Alabama’s ruling stating that reasonable minds could differ as per interpretation from available facts about railroad's potential liability thus reinstating jury verdict awarding Mrs.Mills with $12k damage compensation.

In the dissenting opinion for the case of St. Louis-San Francisco Railway Company v. Mills, it was argued that there should be no distinction between a railway company's liability for injuries to its employees and those to non-employees in cases where negligence is proven. The dissenting justices believed that if an employee suffers injury due to the employer’s negligence, then they are entitled to compensation regardless of whether or not they assumed risk by accepting employment with knowledge of potential dangers inherent in their work environment. They contended that this principle should apply even when dealing with interstate commerce companies such as railways, which have historically been granted certain protections under federal law against state regulations and lawsuits from injured workers seeking damages for workplace accidents caused by employer negligence.