In the case of Still v. Norfolk & Western Railway Co., 1961, the Supreme Court ruled in favor of Norfolk & Western Railway Co. The plaintiff, Mr. Still, was a railway employee who sued his employer for negligence under the Federal Employers' Liability Act (FELA) after he suffered an injury while working on a train car's air brake system that had been modified by another company before being leased to Norfolk & Western Railway Co. He argued that his employer failed to provide him with a safe place to work and did not properly inspect or maintain equipment. The court held that FELA does not impose absolute liability on employers but requires them only to exercise reasonable care in providing safe workplaces and equipment for their employees. It found no evidence suggesting negligence on part of the railway company as it had no reason to suspect any defect in the brake system which caused Mr.Still’s injuries nor was there any proof showing failure from its side regarding inspection or maintenance duties.

In the dissenting opinion for Still v. Norfolk & Western Railway Co., Justice Harlan argued that the majority's decision to allow a state court to exercise personal jurisdiction over an out-of-state defendant, based solely on their business activities within the state, was inconsistent with due process principles. He contended that this ruling expanded traditional notions of fair play and substantial justice beyond acceptable limits. According to him, it was unfair for a corporation conducting continuous and systematic operations in one state to be subjected to suit there on causes of action unconnected with those operations. The mere presence or activity of a company in a particular location should not automatically subject them to legal proceedings unrelated to their actions in that area. In his view, such broad interpretation could potentially expose corporations doing business nationwide or worldwide at risk from being sued anywhere they operate regardless if these suits have no connection whatsoever with their activities in those places.