In the Dillon v. Strathearn Steamship Company case of 1918, a dispute arose over whether or not seamen could claim damages for injuries sustained while working on board a ship due to negligence by their employer under the Jones Act. The plaintiff, Dillon, was injured when he fell through an open hatch that had been left unguarded and sued his employer, Strathearn Steamship Company. The defendant argued that they were exempt from liability as per maritime law which traditionally did not allow seamen to sue their employers for injuries incurred during service. However, the Supreme Court ruled in favor of Dillon stating that the Jones Act extended this right to sailors allowing them to seek compensation if they can prove negligence on part of their employers leading to injury or death.

In the dissenting opinion for Dillon v. Strathearn Steamship Company, Justice Holmes disagreed with the majority's interpretation of The Seamen's Act of 1915. He argued that the act was not intended to give seamen a right to sue their employers for damages in case of injury or death caused by negligence on part of ship officers or crew members. Instead, he believed it merely provided them with maintenance and cure - basic living expenses and medical care while they were recovering from an illness or injury incurred during service at sea. According to him, any additional rights should be explicitly stated in legislation rather than inferred by courts through broad interpretations.