In the case of Venner v. Michigan Central Railroad Company, 1925, the plaintiff, Venner sued for damages after being injured while working as a brakeman on one of the defendant's trains. The injury occurred when he was thrown from a car due to an alleged sudden and unusual jerk or lurch caused by negligent handling of the train by other employees of the company. The Supreme Court held that there was sufficient evidence presented at trial to support a finding that negligence on part of Michigan Central Railroad Company had caused Venner’s injuries. Therefore, it ruled in favor of Venner stating that his claim should not have been dismissed at trial level and remanded it back for further proceedings.

The dissenting opinion in the case of Venner v. Michigan Central Railroad Company argued that the majority's decision to uphold a lower court ruling, which found the railroad company not liable for injuries sustained by an employee due to negligence, was incorrect. The dissent contended that there were sufficient grounds for a reasonable jury to conclude that the railroad had been negligent and thus should be held accountable for damages. They believed it was inappropriate for judges rather than juries to make determinations about factual matters such as whether or not negligence occurred. Furthermore, they asserted that federal law required employers like railroads to provide safe work environments and take precautions against foreseeable risks; failing this duty could constitute negligence under common law principles.