In the 1993 case American Dredging Company v. William Robert Miller, the U.S. Supreme Court ruled that a state law allowing for "forum non conveniens" dismissals was not preempted by federal maritime law. The plaintiff, William Robert Miller, had been injured while working on a barge in Louisiana and sued his employer, American Dredging Company (ADC), under the Jones Act in Pennsylvania court where ADC did business but neither party resided or worked regularly. ADC sought to have the case dismissed based on forum non conveniens - arguing it would be more appropriate to try this case in Louisiana rather than Pennsylvania due to location of witnesses and evidence related to incident. The issue before the Supreme Court was whether federal maritime law preempts states from applying their own laws regarding forum non conveniens dismissals. In an unanimous decision led by Justice Sandra Day O'Connor, they held that there is no general federal policy against such dismissals; therefore state courts may apply their own rules about them without being superseded by federal maritime jurisdiction.

In the dissenting opinion for American Dredging Company v. William Robert Miller, Justice Scalia disagreed with the majority's decision to uphold Pennsylvania law over federal maritime law. He argued that this ruling contradicted previous court decisions which established a uniform national rule in matters of admiralty and maritime jurisdiction. According to him, allowing individual states to impose their own laws would lead to inconsistency and unpredictability in an area where uniformity is essential due to its international nature. Furthermore, he contended that Congress had already provided remedies for seamen injured on navigable waters through federal legislation such as the Jones Act and Longshoremen’s Compensation Act; therefore it was unnecessary for state laws like Pennsylvania's wrongful death statute to be applied here.