In the 1990 case of Exxon Corporation v. Central Gulf Lines, Inc., et al., the U.S. Supreme Court ruled in favor of Exxon Corporation, reversing a previous decision by the Fifth Circuit Court of Appeals. The dispute arose when Exxon chartered a ship from Central Gulf Lines and subsequently sub-chartered it to another company without obtaining consent from Central Gulf Lines as required under their agreement. When an accident occurred causing damage to the vessel, both companies sought compensation for repairs from each other based on different interpretations of their charter party contract's "safe berth" clause which requires charterers to return vessels undamaged except for normal wear and tear. The Supreme Court held that maritime law should be applied rather than state law in interpreting this type of contractual provision because it is more appropriate given its international nature and specialized rules governing shipping activities. Furthermore, they found that under maritime law, safe berth clauses are considered warranties rather than mere due diligence obligations; therefore if breached (as was done by Exxon), liability arises regardless whether negligence or fault can be proven.

In the dissenting opinion for Exxon Corporation v. Central Gulf Lines, Inc., Justice Scalia disagreed with the majority's interpretation of "inland transportation" in the context of a federal tariff statute. He argued that this term should not be limited to land-based transport but should also include river and lake shipping, which is common in many parts of America. He pointed out that historically and legally, inland navigation has been considered as part of 'inland transportation'. Therefore, he believed that Exxon’s oil spill cleanup costs could be classified as “charges for any additional service necessary to effect delivery,” under Item 345(a) of Control Tariff No. A-1918-KK (Tariff). This would mean they are recoverable from Central Gulf Lines under their contract terms. The majority's narrower interpretation was inconsistent with both historical usage and legal precedent according to him.