In the case of Grant Smith-Porter Ship Company v. Rohde, 1921, the United States Supreme Court ruled in favor of a shipbuilding company that had been sued by an employee for injuries sustained on the job. The plaintiff, Mr. Rohde was injured while working on a vessel under construction and sought compensation from his employer based on negligence laws applicable to land-based workplaces. However, the court held that maritime law applied since he was injured aboard a ship - even though it wasn't yet completed or launched at sea during his injury occurrence time. Under maritime law, employers are not liable for accidents caused by fellow employees' carelessness unless there is proof of gross negligence or unseaworthiness which could not be established in this case.

In the dissenting opinion for Grant Smith-Porter Ship Company v. Rohde, Justice Holmes disagreed with the majority's interpretation of the Jones Act and its application to this case. He argued that Congress intended to extend a seaman's right to recover damages for personal injuries under federal law, regardless of whether or not negligence was involved in their injury. In his view, it was irrelevant if an employer had taken all reasonable precautions; if a worker got injured on duty due to any reason related directly or indirectly with work conditions, they should be entitled to compensation under the Jones Act. The majority’s decision contradicted this principle by denying recovery based on lack of proven negligence from employer side which he believed undermined workers' rights and protections as envisioned by Congress when passing this act.