In the Garrett v. Moore-McCormack Co., Inc. et al., 1942 case, the U.S Supreme Court ruled in favor of a seaman who had been injured while working on a ship owned by Moore-McCormack Co., Inc. The plaintiff, Garrett, was awarded damages under both maintenance and cure (a maritime law doctrine requiring a shipowner to provide medical care free of charge to a seaman injured in service of the ship) and indemnity (compensation for harm or loss). The court held that an employer is obligated to pay maintenance and cure until maximum medical recovery has been achieved regardless if it overlaps with any period covered by indemnity payments for lost wages due to unseaworthiness. This decision affirmed that these two types of compensation serve different purposes: one compensates for earnings lost due to injury caused by unseaworthiness; the other provides sustenance during illness or incapacity resulting from employment-related injuries.

In the dissenting opinion for Garrett v. Moore-McCormack Co., Inc., Justice Frank Murphy argued that the majority's decision was a departure from established principles of maritime law and an unwarranted intrusion into legislative territory. He contended that seamen should not be required to prove negligence on part of their employers in order to receive compensation for injuries sustained while working aboard ship, as this requirement would place an undue burden on workers who are often ill-equipped to gather evidence or mount legal defenses. Instead, he advocated for a system where liability is assumed unless the employer can demonstrate they took all reasonable precautions against injury. This approach, he argued, better aligns with longstanding traditions in maritime law which prioritize protecting seamen due to their uniquely vulnerable position within society and economy.