In the case of Atlantic Transport Company of West Virginia v. State of Maryland to the Use of Szczezek, 1913, the Supreme Court ruled in favor of Atlantic Transport Company. The issue at hand was whether a state could impose its own laws on an interstate commerce vessel while it is within that state's jurisdiction. In this instance, a worker named Szczezek had been injured while working on one such ship owned by Atlantic Transport Co., and sought compensation under Maryland law. However, since federal maritime law governed these types of cases involving interstate commerce vessels rather than individual state laws, the court held that Maryland did not have jurisdiction over this matter and thus could not enforce its workers' compensation statute against an out-of-state company like Atlantic Transportation Co.

In the dissenting opinion for Atlantic Transport Company of West Virginia v. State of Maryland to the Use of Szczesek, Justice Holmes disagreed with the majority's interpretation that a state could not impose its own laws on foreign corporations operating within its borders. He argued that states have inherent power to regulate businesses within their jurisdiction and protect their citizens' rights, even if those businesses are incorporated elsewhere. Furthermore, he contended that it was irrelevant whether or not a corporation had consented to such regulation; once they chose to operate in a particular state, they were subject to its laws by default. Thus, according to Justice Holmes’ view, Maryland’s imposition of liability on Atlantic Transport should have been upheld as an exercise of legitimate state authority over business conducted within its territory.