In the case of Union Pacific Railroad Company v. Harris, 1909, the U.S Supreme Court ruled in favor of Union Pacific Railroad Company. The dispute arose when Mrs. Harris sued the railroad company for damages after her husband was killed while working on a construction project for them in Wyoming. She claimed that his death was due to negligence by the company and sought compensation under Nebraska law where they resided. However, since Mr.Harris's contract with Union Pacific stipulated that any legal disputes would be governed by Kansas law (where he signed it), not Nebraska or Wyoming laws, and because Kansas law at that time did not allow such damage claims from widows like Mrs.Harris unless there had been a direct contractual relationship between herself and the railroad which wasn't present here; she lost both at trial court level as well as upon appeal to Supreme Court.

In the dissenting opinion for Union Pacific Railroad Company v. Harris, it was argued that the majority's decision to uphold a verdict in favor of an employee who had been injured on the job was incorrect because there wasn't sufficient evidence to prove negligence on part of the employer. The dissent pointed out that while it is true employers have a duty to provide safe workplaces, this does not mean they are automatically liable for all injuries sustained by employees at work. It must be proven beyond reasonable doubt that an injury resulted directly from an employer's failure to fulfill their duty of care - something which, according to the dissenting justices, did not happen in this case. They believed that upholding such a verdict without clear proof sets a dangerous precedent and could potentially lead to unjust outcomes in future cases involving workplace accidents.