In Ex Parte: In the Matter of Henry W. Rhodes v. The Steamship Galveston, &c., a case heard before the United States Supreme Court in 1850, Henry W. Rhodes brought suit against The Steamship Galveston for damages resulting from an accident that occurred while he was employed as a seaman on board the vessel. At issue was whether or not Rhode's claim could be considered under admiralty law and if so, what amount should be awarded to him for his injuries? After hearing arguments from both sides, the court ruled that Rhode's claim did fall within admiralty jurisdiction and ordered compensation to be paid out accordingly based upon evidence presented by both parties during trial proceedings. Ultimately this decision established precedent which allowed seamen injured at sea to seek redress through admiralty courts when their claims were otherwise barred by state laws or other legal impediments at the time of filing suit.

In the dissenting opinion of Ex Parte: In the Matter of Henry W. Rhodes v. The Steamship Galveston, &c., Justice Catron argued that a libelant's right to recover damages for personal injury should not be limited by any statute or rule of court. He believed that it was unjust and inequitable to deny recovery in cases where an individual had suffered physical harm due to another party’s negligence or wrongful act, regardless of whether such action occurred on land or at sea. Furthermore, he argued that if Congress intended for there to be limitations on liability in maritime cases involving personal injuries, they would have included them explicitly within their statutes rather than leaving it up to courts and judges who may interpret those laws differently from one another. Ultimately, Justice Catron concluded that denying a libelant's right to recover damages based solely upon the fact that his injury occurred at sea was contrary both “to reason and justice” as well as “the spirit which pervades our admiralty jurisprudence."