In the case of Toledo, St. Louis and Western Railroad Company v. Slavin (1914), the U.S Supreme Court dealt with a dispute over an injury claim by a railroad worker under the Federal Employers' Liability Act (FELA). The plaintiff, Slavin, was injured while working for the defendant company when he fell from a moving train due to alleged negligence on part of his employer in providing safe working conditions. The lower court ruled in favor of Slavin awarding him damages; however, this decision was appealed by the railroad company arguing that they were not given fair opportunity to present their defense during trial. The Supreme Court held that there had been no denial of justice as claimed by defendants since they were allowed ample time and opportunity to present all relevant evidence and arguments at trial but failed to do so effectively. Therefore, it upheld the judgment awarded by lower courts in favor of Mr. Slavin stating that employers are liable for injuries sustained by employees due to unsafe work environments under FELA.

In the dissenting opinion for Toledo, St. Louis and Western Railroad Company v. Slavin, it was argued that the majority's decision to hold the railroad company liable for injuries sustained by an employee due to negligence of a fellow servant contradicted established legal principles. The dissenting justices contended that under common law principles, employers were not responsible for accidents caused by employees unless they failed in their duty of care in hiring or supervision. They believed this principle should apply even though federal legislation had been enacted providing otherwise because such laws could not retroactively change contractual relationships between private parties without violating constitutional protections against impairment of contracts. Furthermore, they disagreed with the majority's interpretation of "fellow servants," arguing instead that only those who shared equal authority and responsibility should be considered as such; therefore, a foreman would not be a fellow servant with laborers under his direction.