In the case of Wheeler v. New York, New Haven and Hartford Railroad Company (1899), the U.S Supreme Court ruled in favor of the railroad company. The plaintiff, Wheeler, had sued for damages after a train accident caused by an alleged negligence on part of the railroad company's employees resulted in his injuries. However, he was unable to prove that any specific act or omission by these employees directly led to his injury. The court held that while it is true that employers are responsible for their employee’s actions during work hours under certain circumstances; this liability does not extend to cases where there is no evidence linking an employee's negligent conduct with harm suffered by another party. Therefore, without clear proof establishing such a connection between negligence and injury in this particular instance, Wheeler's claim could not be upheld.

In the dissenting opinion for Wheeler v. New York, New Haven and Hartford Railroad Company, Justice Harlan argued that the majority's decision was inconsistent with previous rulings of the court regarding interstate commerce. He contended that a state cannot regulate or interfere with interstate commerce in any way unless Congress has specifically granted it permission to do so. In this case, he believed that Connecticut had overstepped its bounds by attempting to regulate railroad rates for travel between states without explicit Congressional approval. Furthermore, he disagreed with the majority's interpretation of what constitutes "direct" versus "indirect" effects on interstate commerce, arguing instead for a broader understanding of these terms which would include more types of regulation under federal jurisdiction.