The United States v. Erie Railroad Company case in 1914 revolved around the interpretation of the Safety Appliance Act, which required all trains to be equipped with certain safety devices. The Erie Railroad Company was charged for violating this act as one of its cars lacked secure grab irons or handholds, posing a potential danger to employees and passengers. However, the company argued that since it did not use or move the car on its line but only received it from another railroad for transportation further along its route without any alteration made by them, they should not be held responsible under this law. The Supreme Court ruled against Erie Railroad Company stating that according to Section 2 of the Safety Appliance Act every carrier is liable if any train used on their railway lines does not comply with regulations irrespective of whether such non-compliant cars are owned by them or other companies.

In the dissenting opinion for United States v. Erie Railroad Company, Justice Holmes disagreed with the majority's interpretation of the Safety Appliance Act. He argued that Congress intended to impose absolute liability on railroads for any injuries caused by defective equipment, regardless of whether or not they had knowledge of such defects. According to him, this strict liability was meant as a deterrent and an incentive for railroads to maintain their equipment properly. The majority's decision would undermine this purpose by allowing railroads to escape liability if they could prove ignorance about a defect in their equipment. Furthermore, he contended that it is unreasonable and unfair to expect employees who are injured due to faulty railroad appliances should bear the burden of proving negligence on part of their employers when these workers have no control over maintenance or inspection procedures.