In Calderon v. Atlas Steamship Company (1897), the U.S Supreme Court ruled on a dispute involving maritime law and personal injury compensation. The plaintiff, Calderon, was a longshoreman who sustained injuries while unloading cargo from the defendant's ship in New Orleans. He filed for damages under Louisiana state law which allowed recovery beyond federal limits set by maritime law. However, the defendant argued that since it was an incident at sea, only federal maritime laws should apply which limited their liability to the value of their vessel post-voyage. The court sided with Atlas Steamship Company stating that when incidents occur within navigable waters of United States or involve vessels engaged in interstate or foreign commerce, they fall under exclusive jurisdiction of admiralty courts and are subject to federal laws rather than individual state laws. Therefore, Calderon could not claim damages exceeding those provided by federal statutes even though he had been injured within Louisiana’s territorial boundaries.

In the dissenting opinion for Calderon v. Atlas Steamship Company, Justice White disagreed with the majority's interpretation of maritime law and its application to this case. He argued that a ship owner should not be held liable for damages caused by an independent contractor if they had no control over their actions or operations. According to him, it was unjust to hold the ship owner responsible when they could not have foreseen or prevented the accident from occurring due to lack of control over how work is performed on board their vessel by third parties. Furthermore, he contended that such liability would discourage ship owners from hiring independent contractors altogether out of fear of potential lawsuits, which in turn could negatively impact commerce and trade at sea.