The Union Pacific Railway Company v. Botsford case in 1890 revolved around the issue of personal privacy and bodily integrity. The plaintiff, Mrs. Botsford, was injured when a beam fell from the ceiling at one of Union Pacific's stations. In preparation for trial, Union Pacific requested that she undergo a surgical examination to determine the extent of her injuries but she refused on grounds it violated her right to personal security and dignity as protected by the Fourth Amendment against unreasonable searches and seizures. The Supreme Court ruled in favor of Mrs. Botsford stating that compulsory surgical examinations were not permissible because they infringed upon an individual’s rights to privacy and physical security under common law principles which are embedded within constitutional protections such as those found in the Fourth Amendment.

In the dissenting opinion for Union Pacific Railway Company v. Botsford, Justice Bradley argued that a court-ordered surgical examination did not violate an individual's personal rights and liberties as long as it was conducted in a respectful manner. He contended that such examinations were necessary to ascertain facts relevant to legal proceedings, particularly when physical injuries were claimed by plaintiffs seeking damages. The justice further stated that courts should have the authority to order these examinations under their general power of directing discovery in cases before them. He believed this power was inherent and essential for administering justice effectively without infringing on constitutional protections against unreasonable searches or invasions of privacy.