In the case of Chicago Dock and Canal Company v. Fraley, as Administratrix of Claffy in 1912, the U.S Supreme Court was tasked with deciding on a dispute involving negligence leading to death. The plaintiff's husband had died due to an accident while working for the defendant company. The wife sued for damages under Illinois law which allowed recovery if death resulted from wrongful act or neglect that would have entitled injured party to maintain action and recover damages if death hadn't ensued. However, the defendant argued that since they were operating under federal laws governing interstate commerce at time of incident, only those laws should apply - which did not provide such right to sue for personal injuries resulting in death. The court ruled against this argument stating that state law could be applied even when a business is involved in interstate commerce unless it interferes with said commerce or contradicts federal legislation regarding same subject matter. In this instance neither condition was met so state law prevailed allowing widow her claim.

The dissenting opinion in the case of Chicago Dock and Canal Company v. Fraley, as Administratrix of Claffy, argued that the majority's decision was inconsistent with previous rulings on similar cases. The dissenting justices believed that there should be a clear distinction between accidents occurring within navigable waters and those happening on land or structures adjacent to these waters. They contended that if an accident happened due to a defect in a structure located over navigable waterways, it should not automatically fall under admiralty jurisdiction unless it directly interfered with navigation or maritime commerce. In this particular case, they felt that since the decedent fell from a defective ladder attached to a dock rather than from any vessel or floating object used for navigation purposes, his death did not occur upon navigable waters but instead resulted from negligence ashore; thus making it inappropriate for federal courts' admiralty jurisdiction.