In the 1961 case of Calbeck, Deputy Commissioner, Bureau of Employees' Compensation v. Travelers Insurance Co. et al., the U.S Supreme Court ruled that a worker injured while repairing a ship on navigable waters was entitled to compensation under the Longshoremen's and Harbor Workers' Compensation Act (LHWCA), even if the vessel was not in active maritime service at the time of injury. The court held that Congress intended for LHWCA to cover all injuries occurring upon navigable waters during employment regardless of whether or not they had any connection with traditional maritime activity such as navigation or commerce on these waters. This decision expanded workers’ rights by broadening their eligibility for compensation under federal law.

In the dissenting opinion for Calbeck v. Travelers Insurance Co., Justice Frankfurter argued that the majority's interpretation of the Longshoremen's and Harbor Workers' Compensation Act was incorrect. He believed that Congress intended to limit compensation under this act only to those injuries occurring on navigable waters, not extending it to include all maritime-related injuries regardless of location. The justice contended that by broadening its scope, the court had overstepped its bounds and encroached upon state jurisdiction in matters related to workers' compensation claims. He also expressed concern about potential confusion and litigation resulting from overlapping federal and state jurisdictions in these cases.