The Great Lakes Dredge & Dock Company v. Kierejewski case in 1922 revolved around a wrongful death claim filed by the administratrix of Kierejewski, whose husband died while working on a dredging project for the company. The deceased was employed as an oiler on one of the company's vessels and drowned when he fell into Lake Michigan from a plank connecting two boats. His wife sued under federal maritime law, claiming negligence by his employer led to her husband’s death. The key issue before the Supreme Court was whether this incident occurred within navigable waters and thus subject to federal jurisdiction or if it should be handled under state laws since it happened within three miles off Chicago's shore - traditionally considered Illinois territory. In its decision, the court ruled that even though this accident took place close to shore, it still occurred in navigable waters used for interstate commerce; hence federal maritime law applied. Therefore, Mrs.Kierejewski could pursue her lawsuit against Great Lakes Dredge & Dock Company under these laws rather than being limited to remedies available through Illinois' workers' compensation statute.

In the dissenting opinion for the case of Great Lakes Dredge & Dock Company v. Kierejewski, Justice Holmes argued that the majority's decision to apply state law was incorrect because federal maritime law should have been applied instead. He contended that since the accident occurred on navigable waters and involved a vessel engaged in maritime activity, it fell under federal jurisdiction according to previous precedents set by admiralty cases. Furthermore, he believed that applying state laws would create inconsistencies in rulings involving similar circumstances due to variations between different states' laws. Therefore, he concluded that uniformity could only be achieved if federal maritime law was used as a standard across all jurisdictions.