In the 1912 case of Troxell, Administratrix v. Delaware, Lackawanna & Western Railroad Company, the U.S Supreme Court dealt with a dispute over liability for an employee's death. The plaintiff was the administratrix of George Troxell who died in a railroad accident while working for Delaware, Lackawanna & Western Railroad Company. She claimed that her husband’s death was due to negligence on part of his employer and sought damages under Pennsylvania state law which allowed recovery if an employee's death resulted from another person's negligent act or omission. The defendant argued that since they were incorporated in New York and not Pennsylvania where the incident occurred, they should be exempted from this law as per federal laws governing interstate commerce. However, Justice Lurton delivered the opinion of court stating that although corporations are creations of specific states (in this case New York), when they operate in other states (like Pennsylvania) they must abide by those states' laws unless there is direct conflict with federal legislation. Therefore it was held that Delaware Lackawanna & Western Railroad Co., despite being incorporated elsewhere had to comply with local state laws regarding worker safety and compensation for accidents occurring within their jurisdiction.

In the dissenting opinion for Troxell v. Delaware, Lackawanna & Western Railroad Company, it was argued that the court majority erred in its interpretation of Pennsylvania's wrongful death statute. The dissent contended that this law should be interpreted to allow recovery not only for pecuniary losses suffered by dependents but also for loss of life itself. It was further argued that a more expansive reading of the statute would better align with its purpose and legislative intent - to compensate families who have lost loved ones due to negligence or wrongdoing. The dissent disagreed with the majority’s view which limited damages strictly to economic losses experienced by survivors, arguing instead for a broader understanding encompassing non-economic damages such as pain and suffering endured by deceased victims prior their deaths.