In the 1897 case of Beardsley v. Broom, Administratrix, the U.S Supreme Court was tasked with determining whether a New York law that allowed for damages to be awarded in cases where death was caused by wrongful act or neglect applied to maritime accidents. The plaintiff's husband died as a result of an accident on Lake Erie and she sought compensation under this state law from the defendant who owned the vessel involved in the incident. However, it was argued that such matters fell under federal jurisdiction due to their maritime nature and thus were not subject to state laws. The court ruled in favor of this argument stating that while states have power over internal commerce including navigation within harbors and rivers, they do not possess authority over navigable waters connecting two or more states which are considered highways of interstate commerce. Therefore, it concluded that only Congress has power over these waters and can create legislation regarding them; hence New York’s statute did not apply.

In the dissenting opinion for Beardsley v. Broom, 1897, it was argued that the court erred in its decision to uphold a lower court's ruling which dismissed a claim by an estate administrator against an insurance company. The dissenting justices believed that there were valid grounds for the case to proceed and disagreed with their colleagues' interpretation of existing laws regarding life insurance policies and beneficiary rights. They contended that Mrs. Beardsley had a legitimate interest in her husband's policy as she was named as his beneficiary before he changed it without her knowledge or consent shortly before his death. The dissenters felt this action constituted fraud on Mr.Beardsley’s part and thus should not be legally upheld, arguing further that Mrs.Beardsley should have been allowed to present evidence supporting these claims rather than having them summarily dismissed by the courts.