The U.S. Supreme Court case Furness, Withy & Company, Limited v. Yang-Tsze Insurance Association, Limited et al., 1916 revolved around a dispute over an insurance claim for damages to the ship "Turret Crown." The British company Furness, Withy & Co owned the vessel and had insured it with several companies including Yang-Tsze Insurance Association. After suffering damage in a storm at sea during its voyage from Japan to India in 1909-10, the owners claimed compensation under their insurance policy but were denied by some of their insurers on grounds that they had not disclosed certain information before taking out the policy - specifically about previous damage suffered by another ship they owned which was similar to Turret Crown. The court ruled against Furness stating that while there is no general duty of disclosure between parties negotiating contracts under American law; however when it comes to marine insurance policies English law applies (as per agreement between parties) where such duty exists and non-disclosure can lead to voiding of contract.

In the dissenting opinion for Furness, Withy & Company, Limited v. Yang-Tsze Insurance Association, Limited et al., Justice Holmes argued that the majority's decision was based on an incorrect interpretation of maritime law and contract principles. He contended that under international maritime law, a ship owner is not liable for damages caused by a fire unless it can be proven they were negligent or at fault. In this case, he believed there was no evidence to suggest negligence on part of Furness, Withy & Co., thus they should not be held responsible for the cargo damage resulting from spontaneous combustion during transport. Furthermore, he disagreed with the majority’s view about insurance contracts covering such losses; according to him these are separate issues and one does not necessarily imply liability in another context.