In the 1915 case of Texas & Pacific Railway Company v. Rigsby, the U.S. Supreme Court ruled in favor of a railway worker who was injured due to his employer's violation of a federal safety statute. The court held that an employee could sue for damages if they were injured as a result of their employer's non-compliance with such statutes, even if the laws themselves did not explicitly provide for this right to sue. This ruling established an important precedent in American law: it confirmed that when Congress passes legislation intended to protect certain groups (in this case, railway workers), those individuals can typically seek legal remedies if their rights under these laws are violated.

In the dissenting opinion for Texas & Pacific Railway Company v. Rigsby, Justice McReynolds disagreed with the majority's decision to allow a private right of action under a federal statute that did not explicitly provide one. He argued that it was not within the Court’s jurisdiction to create such an implied cause of action and believed this should be left up to Congress. Furthermore, he expressed concern about potential abuse by plaintiffs who might take advantage of this ruling in order to seek damages from corporations even when they themselves had suffered no personal injury or loss as a result of alleged statutory violations. This could lead, he warned, to excessive litigation and unwarranted financial burdens on businesses.