In the 1938 case of Bethlehem Steel Co. v. Zurich General Accident & Liability Ins. Co., the U.S Supreme Court ruled in favor of Bethlehem Steel Company, reversing a lower court's decision that had favored Zurich Insurance Company. The dispute arose from an insurance policy issued by Zurich to cover damages for which Bethlehem might become liable under the Longshoremen's and Harbor Workers' Compensation Act due to injuries sustained by its employees during their employment period on navigable waters within United States jurisdiction or upon any dry dock owned or operated by them within such jurisdictional limits. When one employee was injured while working on a floating crane outside territorial waters, but still within US admiralty jurisdiction, Zurich refused coverage arguing that it only covered accidents occurring "within" U.S territory as defined in the policy terms and conditions; hence not covering incidents happening beyond three miles off-shore where this accident occurred. The Supreme Court disagreed with this interpretation stating that 'within' should be interpreted broadly to include all areas under U.S maritime control regardless of geographical boundaries since these were places where federal law applied including workers’ compensation laws like those at issue here.

The dissenting opinion in the Bethlehem Steel Co. v. Zurich General Accident & Liability Ins. Co., case argued that the majority's interpretation of the insurance contract was too narrow and failed to consider its broader implications. They contended that, under a more comprehensive understanding of the agreement, Bethlehem Steel should be held liable for damages resulting from accidents on their property even if they were not directly responsible for them. The dissenters believed this interpretation would better align with general principles of liability law and provide greater protection for individuals harmed by such incidents.