In the 1984 case of St. Louis Southwestern Railway Co. v. Dickerson, the United States Supreme Court ruled in favor of St. Louis Southwestern Railway Co., overturning a lower court's decision that had awarded damages to an employee, Dickerson, under the Federal Employers' Liability Act (FELA). The FELA allows railroad workers to sue their employers for injuries sustained on the job due to negligence by their employer or co-workers. However, in this case, it was determined that there was insufficient evidence presented at trial demonstrating such negligence on part of the railway company leading directly to Mr.Dickerson’s injury and subsequent disability claim; therefore he could not be compensated under FELA provisions as per previous ruling by Arkansas Supreme Court.

In the dissenting opinion for St. Louis Southwestern Railway Co. v. Dickerson, Justice Brennan disagreed with the majority's interpretation of the Federal Employers' Liability Act (FELA). He argued that FELA was designed to provide broad protection for railroad workers and should be interpreted liberally in their favor. The majority held that a worker could not recover damages under FELA unless he or she could prove negligence on part of the employer, but Brennan contended this requirement was too strict and inconsistent with Congress's intent when it enacted FELA. Instead, he believed any injury occurring during employment should be compensable regardless of whether there is proof of negligence by an employer.