In the 1994 case of Chandris, Inc. v. Antonios Latsis, the U.S Supreme Court was tasked with determining whether or not a ship's radio electronics officer could be considered a "seaman" under the Jones Act - an act providing legal protection to seafarers injured in maritime accidents due to negligence by their employers. The plaintiff, Antonios Latsis had developed an eye condition while working on board and sued his employer for damages claiming that he was entitled to protections under this Act as he spent more than 30% of his time in service of a vessel on navigable waters. The court ruled in favor of Latsis stating that any worker who spends at least 30% of their time contributing to function or mission aboard vessels qualifies as a seaman under the Jones Act regardless if they perform traditional blue-water navigation functions.

In the dissenting opinion for Chandris, Inc. v. Antonios Latsis (1994), Justice Stevens argued that the majority's interpretation of "seaman" under the Jones Act was too restrictive and inconsistent with congressional intent. He contended that Congress intended to provide broad protection for maritime workers, including those who spend a significant amount of their time in service of a vessel on navigable waters but do not contribute to its function or mission. According to Justice Stevens, such an interpretation would better align with previous court decisions and legislative history indicating that seamen should be defined broadly rather than narrowly. Furthermore, he criticized the majority's use of a percentage-based test as arbitrary and unworkable in practice because it fails to account for variations in employment arrangements among different types of vessels and maritime industries.