The U.S. Supreme Court case Alaska Packers Association v. Industrial Accident Commission et al., 1927, involved a dispute over workers' compensation for nonresident alien seasonal laborers in the salmon canning industry in Alaska. The plaintiff, Alaska Packers Association (APA), argued that California's Industrial Accident Commission had no jurisdiction to award benefits to injured workers who were residents of Mexico and contracted outside of California but got injured while working in Alaska under contracts governed by Alaskan law. However, the court ruled against APA stating that although the employment contract was made in Mexico and intended to be performed in Alaska, it was not entirely extraterritorial as some part of it was performed within California when they traveled from San Francisco to their work destination on ships owned by APA which constituted an integral part of their service. Therefore, these employees were entitled to receive worker’s compensation under Californian law despite being non-resident aliens.

In the dissenting opinion for Alaska Packers Association v. Industrial Accident Commission, Justice Oliver Wendell Holmes Jr. argued that the case should be decided based on principles of federalism and comity rather than constitutional law. He contended that California's workers' compensation laws were applicable to injuries sustained by Alaskan cannery workers while in transit from San Francisco because they had been hired there under contracts governed by California law. According to Holmes, it was not a violation of due process or equal protection for California to apply its own laws within its borders even if those laws affected out-of-state activities indirectly. Furthermore, he believed that any potential conflicts between state and federal jurisdiction could be resolved through negotiation and cooperation among states rather than judicial intervention.