In the case of Calais Steamboat Co. vs Scudder, Adm'r of Van Pelt, the Supreme Court was asked to decide whether a steamboat company could be held liable for damages caused by an explosion on board one of its vessels. The court found that while it is true that steamboats are inherently dangerous and accidents may occur without fault or negligence on behalf of either party, in this particular instance there had been evidence presented which showed that the accident was due to improper maintenance and operation by the steamship company's employees. As such, they were held responsible for any resulting damage or injury suffered by passengers as a result of their actions. Furthermore, since it was determined that these actions constituted negligence on behalf of the steamship company itself rather than simply being an unavoidable incident related to operating a vessel at sea, they were required to pay compensation accordingly.

In the dissenting opinion of Calais Steamboat Co. vs. Scudder, Adm'r of Van Pelt, Justice Grier argued that the deceased's estate should not be held liable for damages caused by a steamboat collision due to his negligence in failing to provide proper lighting on board the vessel. He reasoned that since there was no legal requirement at the time for vessels to have lights and since it was common practice among other boats not to carry them, it would be unfair and unjustified to hold this particular boat owner responsible for an accident which he could not have foreseen or prevented without violating accepted customs of navigation. Furthermore, Justice Grier noted that even if such a duty had been imposed upon him by law prior to the incident in question, he still could not be held accountable because he did nothing wrong; rather than being negligent himself, he simply failed to comply with regulations which were never established until after his death when they became retroactively applicable under maritime law.