In the case of Texas and Pacific Railway Company v. Carlin, 1902, the U.S Supreme Court ruled in favor of the railway company. The dispute arose when John Carlin filed a lawsuit against the railway company for damages after he was injured while working as a brakeman due to alleged negligence on part of his employer. However, it was found that Carlin had violated a rule set by his employer which required him to not step off moving trains unless necessary for performing duties or preventing accidents. Despite this rule being communicated clearly to all employees including Carlin himself, he chose to ignore it leading up to his injury. The court held that an employee who knowingly violates such rules cannot hold their employers liable for any resulting injuries under common law principles governing master-servant relationships (employer-employee relations). Therefore, even though there might have been some negligence on part of Texas and Pacific Railway Company regarding safety measures at work place; since Mr.Carlin consciously broke an established safety rule without any compelling reason or necessity related directly with performance of duty or prevention of accident; he could not claim compensation from them.

The dissenting opinion in the case of Texas and Pacific Railway Company v. Carlin argued that the majority's decision to uphold a lower court ruling, which held the railway company liable for damages incurred by Carlin due to an accident caused by negligence on part of its employees, was erroneous. The dissent contended that there was insufficient evidence presented at trial to prove beyond reasonable doubt that negligence from railway employees directly resulted in Carlin's injuries. It further asserted that it is not enough merely to show possibility or even probability of such causation; rather, it must be demonstrated with certainty. Therefore, according to this view, since no direct link between employee negligence and injury could be established conclusively during trial proceedings, liability should not have been imposed upon the railway company.