In the 1962 case Gutierrez v. Waterman Steamship Corp., the U.S. Supreme Court ruled in favor of a foreign seaman who had been injured while working on an American ship docked in a foreign port. The plaintiff, Mr. Gutierrez, was a Honduran citizen employed by an American company on their ship when he suffered injuries due to negligence and unseaworthiness of the vessel while it was docked in Cuba. He filed suit under general maritime law for damages against his employer, Waterman Steamship Corporation. The main issue before the court was whether or not United States courts could exercise jurisdiction over such cases involving accidents that occurred outside U.S territorial waters but involved American companies employing foreign workers aboard their ships. The Supreme Court held that federal courts did have jurisdiction over these types of claims and affirmed Mr.Gutierrez's right to sue his employers under general maritime law for damages resulting from negligence and unseaworthiness. This ruling expanded protections for international laborers working on US vessels abroad, recognizing them as part of its scope despite incidents occurring beyond domestic borders.

In the dissenting opinion for Gutierrez v. Waterman Steamship Corp., Justice Harlan argued that the majority's decision to allow a foreign plaintiff to sue an American corporation under U.S. law was inconsistent with international legal principles and could potentially harm U.S.-foreign relations. He contended that, in cases involving foreign plaintiffs and incidents occurring outside of the United States, it would be more appropriate to apply the laws of the country where the incident occurred rather than automatically applying U.S. law simply because one party is an American corporation. This approach, he suggested, would better respect international sovereignty and prevent potential diplomatic conflicts arising from perceived overreach by U.S courts into matters properly within another nation’s jurisdiction.