In the case of Union Pacific Railroad Company v. Hadley, Administrator of Cradit (1917), the Supreme Court examined a dispute over damages awarded to an injured employee under Kansas state law. The plaintiff, Hadley, was acting on behalf of Cradit who had been severely injured while working for Union Pacific Railroad Company and sought compensation under Kansas' Employer's Liability Act. The railroad company argued that this state law conflicted with federal laws governing interstate commerce and thus should not apply in this instance as they were engaged in such commerce at the time of injury. However, the court ruled against them stating that there was no conflict between federal and state laws because both aimed to protect employees from harm caused by negligence or carelessness on part of their employers. Therefore, it upheld the lower courts' decision awarding damages to Cradit.

The dissenting opinion in the case of Union Pacific Railroad Company v. Hadley, argued that the majority's decision to hold a railroad company liable for damages caused by an employee who was not acting within his scope of employment at the time of incident is unjust and sets a dangerous precedent. The dissent emphasized that employers should only be held responsible for actions committed by their employees while they are performing duties related to their job. In this particular case, it was noted that the conductor had acted out of personal malice rather than as part of his professional responsibilities when he ejected Cradit from the train, leading to his death. Therefore, according to this view, Union Pacific Railroad Company should not have been held accountable for Cradit's demise.