The Union Pacific Railroad Company v. Huxoll case in 1917 revolved around the death of an employee, Mr. Huxoll, who was killed while working on a railroad construction project in New Mexico for the Union Pacific Railroad Company. The main issue at hand was whether or not his widow could sue for damages under Nebraska law (where they resided) even though the accident occurred in New Mexico and he had been hired in Kansas. The Supreme Court ruled that Mrs. Huxoll could indeed file her claim under Nebraska law because it provided more favorable terms than either Kansas or New Mexico's laws regarding compensation for workplace fatalities, despite neither party being physically present there when the contract was made nor when injury occurred.

The dissenting opinion in the case of Union Pacific Railroad Company v. Huxoll, 1917, argued that the majority's ruling was inconsistent with previous decisions and failed to properly interpret Nebraska law. The dissent contended that under Nebraska law, a railroad company is liable for damages resulting from fires caused by its locomotives unless it can prove it took all possible precautions to prevent such fires. In this case, the dissent believed there was sufficient evidence presented at trial showing that Union Pacific had not taken all necessary precautions and therefore should be held responsible for the fire damage suffered by Huxoll. They disagreed with the majority's view that negligence needed to be proven on part of Union Pacific; instead they asserted existing state laws already established liability without need for further proof of negligence.