In the case of Butts v. Merchants & Miners Transportation Co., 1912, the U.S Supreme Court ruled in favor of the defendant, Merchants and Miners Transportation Company. The plaintiff, Mr. Butts had sued for damages after he was injured while working on one of their steamships due to a defective tool provided by his employer. However, it was found that Mr. Butts had been aware of this defect but continued to use it anyway without complaint or request for replacement; thus voluntarily assuming risk associated with its usage. The court held that under maritime law (which governed this case), an employee cannot recover damages from an employer if they knowingly and willingly expose themselves to danger - even if said danger is caused by negligence on part of the employer in providing faulty equipment or tools. This ruling reinforced two key principles: firstly, employers' liability can be limited under certain circumstances where employees contribute towards their own injury through reckless behavior; secondly, maritime workers are subject to different legal standards compared to land-based workers when seeking compensation for workplace injuries.

The dissenting opinion in the case of Butts v. Merchants & Miners Transportation Co., argued that the majority's decision to hold a steamship company liable for damages due to an injury sustained by a passenger was incorrect. The dissent asserted that there was no evidence showing negligence on part of the ship's crew or officers, and thus, they should not be held responsible for unforeseeable accidents. They contended that it is unreasonable to expect absolute safety in such situations as sea travel inherently involves some risk which passengers willingly accept when they choose this mode of transportation. Therefore, unless clear proof of negligence can be demonstrated, companies should not bear liability for unfortunate incidents beyond their control.