In the 1913 case of Young v. Central Railroad Company of New Jersey, the plaintiff, Mrs. Young, sued on behalf of her deceased husband who was killed in a train accident while working for the defendant company as a brakeman. The Supreme Court had to decide whether or not an employer could be held liable under federal law for injuries sustained by their employees due to negligence from fellow workers (the "fellow servant rule"). The court ruled that under the Federal Employers' Liability Act (FELA) passed in 1908, employers were indeed responsible for such injuries and deaths caused by co-worker negligence if they occurred during interstate commerce activities. This ruling effectively nullified state laws upholding the “fellow servant rule” which previously protected companies from liability in these situations.

In the dissenting opinion for Young v. Central Railroad Company of New Jersey, Justice Holmes disagreed with the majority's ruling that a railroad company could be held liable for an employee's death caused by another employee’s negligence under New Jersey law. He argued that while it was true that employers were generally responsible for their employees' actions during work hours, this principle should not apply when both parties involved in an accident were employees of the same company and performing their duties at the time of incident. According to him, such situations should instead be governed by internal rules and regulations set up by companies themselves rather than state laws designed to protect third parties from harm caused by employees’ negligent acts. Furthermore, he believed there was no evidence showing that railroads had been historically treated differently from other types of businesses regarding employer liability issues under common law or statutory provisions in place at the time.