In the 1916 case of George Schwede v. Zenith Steamship Co., the U.S Supreme Court ruled in favor of Zenith Steamship Company, reversing a previous decision by the Circuit Court of Appeals for the Second Circuit. The dispute arose when George Schwede, an employee on one of Zenith's ships, was injured while working and sought compensation under maritime law. However, his injury occurred not at sea but while docked in port loading cargo onto the ship from a warehouse owned by another company. The court held that since he was injured on land rather than aboard ship or on navigable waters (the traditional jurisdictional boundaries for admiralty law), his claim did not fall within federal maritime jurisdiction and should be pursued through state workers' compensation laws instead.

The dissenting opinion in the case of George Schwede v. Zenith Steamship Co., 1916, argued that the majority's decision was inconsistent with previous rulings and failed to adequately consider maritime law principles. The dissent emphasized that a seaman injured while performing his duties has an absolute right to maintenance and cure under maritime law, regardless of negligence or unseaworthiness on part of the shipowner. It further contended that this right should not be limited by any contractual agreement between the parties involved as it is a public policy matter designed to protect sailors who are often at disadvantageous positions when negotiating employment contracts. Therefore, according to this view, Mr.Schwede should have been entitled to receive compensation for his injuries even if he had signed an agreement limiting his rights before embarking on the voyage during which he got injured.