In the case of Ward v. Atlantic Coast Line Railroad Co., 1959, the U.S Supreme Court dealt with a dispute over whether an employer was liable for injuries sustained by an employee due to negligence on part of another employee. The plaintiff, Ward, was injured while working as a switchman for Atlantic Coast Line Railroad when he fell from a ladder that had been negligently left in place by another worker. He sued his employer under the Federal Employers' Liability Act (FELA), which holds railroads accountable for injuries to their employees resulting from co-worker negligence. The lower courts ruled in favor of the railroad company stating that it could not be held responsible because there wasn't any proof that they were aware or should have been aware about such negligent behavior among its employees. However, upon appeal to the Supreme Court, this decision was reversed and remanded back to trial court level. The Supreme Court stated that FELA's purpose is not only compensatory but also meant to promote safety in railroad operations; hence employers can be held liable even if they weren’t directly at fault or didn't know about specific acts of negligence committed by their workers.

In the dissenting opinion for Ward v. Atlantic Coast Line Railroad Co., Justice Brennan disagreed with the majority's interpretation of the Federal Employers' Liability Act (FELA). He argued that FELA was designed to shift responsibility for employee injuries from workers to their employers, and thus should be interpreted broadly in favor of injured employees. The majority held that a railroad worker could not recover damages under FELA unless he proved negligence on part of his employer. However, Brennan believed this requirement was too strict and contrary to congressional intent. Instead, he suggested that an employee should only have to prove that his injury resulted from work-related risks created or enhanced by the employer - regardless if there is proof of negligence or not. This approach would better align with Congress's goal when it enacted FELA: protecting railroad workers from bearing financial burdens resulting from job-related injuries.