The United States Supreme Court case, United States v. New York Central Railroad Company, Lessee (1928), revolved around the interpretation of a federal statute that imposed penalties on railroads for accidents caused by their employees' negligence. The New York Central Railroad argued that it should not be held liable because it had no control over its employees' actions and could not have foreseen or prevented the accident in question. However, the court ruled against them stating that under common law principles of vicarious liability, an employer is generally responsible for the negligent acts of its employees committed within their scope of employment. Therefore, even though they did not directly cause or could foresee such accidents themselves but as long as these were due to employee's negligence during work hours and within job responsibilities then they are still accountable according to law.

The dissenting opinion in the United States v. New York Central Railroad Company case argued that the majority's decision to hold corporations criminally liable for actions of their employees, even if those actions were against company policy or unknown to management, was unjust and could lead to unfair punishment. The dissenters believed this ruling would unfairly penalize corporations for acts they had no knowledge of and did not authorize. They contended that a corporation should only be held responsible when it has directly authorized an illegal act or failed in its duty to prevent such action through negligence or recklessness. This perspective emphasized individual responsibility over collective liability, arguing that punishing a corporation does not necessarily deter individuals within it from committing unlawful acts.