In the 1936 case of Foust, Administrator v. Munson Steamship Lines, the United States Supreme Court ruled on a dispute involving maritime law and wrongful death claims. The administrator of a deceased seaman's estate sought to recover damages for his death under federal statutes that provide remedies for injuries or deaths caused by negligence at sea. However, the lower court dismissed this claim because it was not filed within two years after the decedent's death as required by New York state law. On appeal, the Supreme Court held that while state laws can supplement federal maritime law in some instances when there is no applicable federal statute, they cannot limit or modify any substantive right conferred by such legislation. Therefore, since Congress had provided a three-year limitation period for bringing wrongful death actions under maritime law (Jones Act), this superseded New York’s shorter time frame and allowed Foust’s claim to proceed.

In the dissenting opinion for Foust v. Munson Steamship Lines, Justice Cardozo disagreed with the majority's decision to award damages to a seaman who was injured due to his own negligence. He argued that this ruling contradicted established principles of maritime law and common sense, which typically do not allow individuals to recover damages caused by their own carelessness. Furthermore, he contended that such an interpretation could lead to absurd results where a seaman might be rewarded for reckless behavior while on duty. Justice Cardozo believed that it is unjustifiable and against public policy interests in promoting safety at sea if sailors are allowed compensation even when they themselves are responsible for their injuries through negligent or careless actions.