The U.S. Supreme Court case Compania de Navegacion Interior, S.A., v. Fireman's Fund Insurance Company in 1927 revolved around a dispute over insurance coverage for a ship that was damaged during the Mexican Revolution. The plaintiff, Compania de Navegacion Interior (a shipping company), sought to recover from its insurer, Fireman's Fund Insurance Company, for damages sustained by one of its vessels while it was being used by revolutionaries. The key issue at hand was whether or not an exclusion clause in the insurance policy - which stated that losses caused by "barratry" (fraudulent conduct on part of the master or crew) were not covered - applied to this situation where the vessel had been seized and used without consent of owners due to civil war conditions. The court ruled in favor of Compania de Navegacion Interior stating that such use did not constitute barratry as there wasn't any fraudulent act committed by master or crew against ship-owner’s interest but rather it was forced upon them due to circumstances beyond their control.

In the dissenting opinion for Compania de Navegacion Interior, S. A., v. Fireman's Fund Insurance Company, Justice Oliver Wendell Holmes argued that the majority had misinterpreted both the terms of the insurance policy and relevant maritime law. He contended that under a proper understanding of these areas, it was clear that Fireman's Fund should be held liable for damages to Compania de Navegacion’s ship following an explosion in Havana Harbor in 1917. According to Holmes, this incident fell within the scope of "war risks" covered by their insurance agreement because it occurred during a period when Cuba was experiencing significant political unrest and violence related directly to World War I. Therefore, he believed that denying coverage based on technicalities about what constitutes war or insurrection was unjustified.