In the case of St. Paul, Minneapolis and Manitoba Railway Company v. Greenalgh (1890), the U.S Supreme Court ruled in favor of the railway company, overturning a lower court's decision that had awarded damages to Greenalgh for injuries he sustained while working on one of their trains. The Supreme Court found that there was insufficient evidence to prove negligence on part of the railway company as required by law for an employee to recover damages from his employer at that time. The court held that it was not enough for an injured employee to show merely that he had been hurt while doing his job; rather, he must also demonstrate some specific act or omission by his employer which directly caused his injury. In this case, no such proof was provided hence ruling in favor of St.Paul, Minneapolis and Manitoba Railway Company.

In the dissenting opinion for the case of St. Paul, Minneapolis and Manitoba Railway Company v. Greenalgh, it was argued that the majority's decision to uphold a lower court ruling in favor of Greenalgh was incorrect due to an improper interpretation of legal precedent and contract law principles. The dissent contended that the railway company had not breached its contractual obligations as claimed by Greenalgh because there were no explicit terms within their agreement stipulating how quickly freight needed to be transported or what specific route should be taken during transit. Furthermore, they believed that any delays experienced were reasonable given various uncontrollable factors such as weather conditions or mechanical issues which are common occurrences in railway operations. Therefore, according to this viewpoint, holding the company liable for damages based on these grounds would set a dangerous precedent where businesses could potentially face excessive litigation over minor inconveniences caused by circumstances beyond their control.