In the case of Boudoin v. Lykes Brothers Steamship Co., Inc., 1954, the U.S. Supreme Court ruled in favor of a seaman who was injured while working on a ship owned by Lykes Brothers Steamship Company. The plaintiff, Boudoin, had been ordered to clean an area near some steam pipes and suffered burns when he accidentally turned a valve releasing hot steam onto himself. He sued under the Jones Act for negligence and unseaworthiness of vessel but lost at trial court level as it found no negligence or unseaworthiness present. However, upon appeal to the Supreme Court, it reversed this decision stating that there was indeed evidence supporting both claims made by Boudoin - negligence due to lack of proper instructions about handling valves and unseaworthiness because safety latch on valve was broken which could have prevented accident if functional. Thus, even though injury resulted from his own inadvertent act (turning valve), employer's failure in providing safe work environment contributed significantly towards occurrence of such incident making them liable for damages.

In the dissenting opinion for Boudoin v. Lykes Brothers Steamship Co., Inc., Justice Robert H. Jackson, joined by Justices Harold Burton and Tom C. Clark, argued that the majority's decision to award damages under the Jones Act was incorrect because it expanded its scope beyond what Congress intended when they passed it in 1920. The dissenters believed that this law should only apply to cases where negligence is proven on part of the employer or fellow employees which resulted in injury or death of a seaman during his employment at sea; not simply due to dangerous conditions inherent in maritime work like rough seas as interpreted by majority justices. They also pointed out that there were other legal remedies available for such situations outside of this act, including maintenance and cure claims under general maritime law which provides compensation without proving fault.