In St. Paul, Minneapolis & Manitoba Railway Company v. Burton, the Supreme Court of the United States was asked to decide whether a railroad company was liable for damages caused by a train accident. The plaintiff, Burton, was injured when a train operated by the defendant railroad company collided with a wagon he was driving. The railroad company argued that it was not liable for the accident because it had taken all reasonable precautions to prevent it. The Supreme Court held that the railroad company was liable for the accident. The Court reasoned that the railroad company had a duty to use reasonable care to prevent accidents, and that it had failed to do so in this case. The Court noted that the railroad company had failed to provide adequate warning of the approaching train, and that it had failed to take other reasonable precautions to prevent the accident. The Court concluded that the railroad company was liable for the damages caused by the accident.

In St. Paul, Minneapolis & Manitoba Railway Company v. Burton, the Supreme Court was asked to decide whether a railroad company could be held liable for injuries caused by its negligence when it had been released from liability in an earlier settlement agreement with the injured party's employer. The majority opinion found that the release did not apply because it only covered claims against employers and not those against third parties such as railroads; however, Justice Harlan dissented on this point. He argued that since both parties were aware of the potential danger posed by working near a railway line and yet still entered into an agreement releasing all claims related to any injury or death resulting from work-related activities at said location, then they should be bound by their contract regardless of who is ultimately responsible for causing harm or damage due to negligence. Furthermore, he noted that if one party can unilaterally void a contract simply because another entity may have been negligent instead of them then no agreements would ever be binding which would lead to chaos in commerce and industry across America.