In the 1943 case of Walton, Administratrix v. Southern Package Corporation, the Supreme Court was asked to determine whether a state court could exercise jurisdiction over an out-of-state corporation that had no physical presence in the state but did have contracts with independent contractors who operated within it. The plaintiff, Mrs. Walton, was seeking damages for her husband's death which occurred while he was working as an independent contractor for Southern Package Corporation in Georgia - a company incorporated and primarily operating in Tennessee. The defendant argued that because they didn't have any offices or employees based in Georgia and their only connection to the state were through these independent contracts, they couldn't be sued there. The Supreme Court ruled against Southern Package Corporation stating that even though corporations may not physically operate within a certain jurisdiction if their activities are substantial and continuous enough (such as having multiple ongoing contracts), then those states can assert personal jurisdiction over them under due process clause of Fourteenth Amendment.

In the dissenting opinion for Walton v. Southern Package Corporation, Justice Frank Murphy argued that the majority's decision to uphold a state law allowing employers to limit their liability in workers' compensation cases was fundamentally unfair and unconstitutional. He contended that such laws disproportionately burdened injured employees by forcing them to bear the cost of workplace accidents, while simultaneously protecting employers from any significant financial responsibility. Furthermore, he believed this violated principles of equal protection under the Fourteenth Amendment because it created an arbitrary distinction between different classes of workers based on their ability or inability to prove negligence on part of their employer. In his view, all injured workers should be entitled to fair compensation regardless of whether they could establish fault.