In the Union Pacific Railway Company v. James case of 1895, the U.S Supreme Court ruled in favor of the railway company. The dispute arose when a train conductor named James was injured while on duty due to an alleged negligence by his employer, Union Pacific Railway Company. He sued for damages and won at both district court level and Nebraska's supreme court level. However, upon reaching the U.S Supreme Court, it was determined that there had been no violation or neglect of duty by Union Pacific towards its employee as claimed by James. The court held that employers are not obligated to ensure absolute safety but rather reasonable care for their employees' safety under normal circumstances; hence they cannot be held liable for all accidents occurring during work hours unless proven negligent or careless about workers' safety conditions.

In the dissenting opinion for Union Pacific Railway Company v. James, Justice Brewer argued that the court majority had erred in its interpretation of the law and its application to this case. He contended that a railroad company should not be held liable for damages caused by an employee's negligence if it was not proven that the company itself was negligent or at fault. According to him, holding companies responsible for their employees' actions without proof of corporate negligence would set a dangerous precedent and could potentially lead to unjust outcomes in future cases involving similar circumstances. He believed that such liability should only apply when there is clear evidence showing direct involvement or neglect on part of the corporation itself.