In the case of Stewart, Administrator v. Southern Railway Co., 1941, the Supreme Court was tasked with deciding whether a railway company could be held liable for injuries sustained by an employee who fell from a moving train due to defective equipment. The plaintiff argued that under the Federal Employers' Liability Act (FELA), which holds railroads responsible for employees' work-related injuries resulting from negligence, Southern Railway should compensate him for his damages. However, Southern Railway contended that they were not at fault because the defect in question had been hidden and undetectable during regular inspections. The Supreme Court ruled in favor of Stewart stating that even if defects are concealed or difficult to detect during routine inspection procedures, railroad companies still have an absolute duty under FELA to provide safe working conditions and equipment for their employees.

In the dissenting opinion for Stewart, Administrator v. Southern Railway Co., Justice Black disagreed with the majority's interpretation of the Federal Employers' Liability Act (FELA). He argued that FELA was intended to provide broad protection for railroad workers and their families against injuries sustained in interstate commerce. The majority held that a worker who had been injured while working on an intrastate train could not recover under FELA because he was not engaged in interstate commerce at the time of his injury. However, Justice Black contended that this narrow interpretation contradicted Congress’s intent when it enacted FELA. He believed that any employee contributing to interstate commerce should be protected by federal law regardless of whether they were directly involved in such activities at the exact moment of injury or death.