In the case of Alcoa Steamship Co., Inc. v. United States (1949), the Supreme Court ruled in favor of the U.S government, upholding a lower court's decision that Alcoa was liable for damages to a naval vessel during World War II. The USS Juneau had been docked next to an Alcoa ship when it was damaged by an explosion on board the latter vessel. The company argued that they were not responsible as they could not have foreseen such an event and therefore did not owe compensation under maritime law principles known as "force majeure" or "Act of God". However, both courts rejected this argument stating that while war conditions might increase risk, they do not absolve parties from their duty to exercise reasonable care nor exempt them from liability for negligence.

In the dissenting opinion for Alcoa Steamship Co., Inc. v. United States, Justice Jackson disagreed with the majority's ruling that a ship owner could be held liable for damages caused by an independent contractor's negligence during loading operations. He argued that this decision contradicted established maritime law and common law principles which typically absolve employers from liability for their independent contractors' actions unless they have direct control over them or their work involves inherently dangerous activities. Furthermore, he contended that imposing such liability on ship owners would unfairly burden them with risks they cannot control or insure against and potentially disrupt shipping commerce due to increased costs of doing business.