In Guzman v. Pichirilo, the U.S. Supreme Court ruled on a case involving maritime law and warranty of seaworthiness for rented vessels. The petitioner, Guzman, had chartered a yacht from the respondent, Pichirilo. During their voyage at sea, a fire broke out in the engine room due to an electrical fault which resulted in total loss of power and left them stranded until they were rescued by Coast Guard cutter. No one was injured but personal property was lost or damaged during this incident. Guzman sued Pichirilo claiming that he had breached his absolute duty under maritime law to provide a seaworthy vessel fit for its intended use - pleasure cruising - because it caught fire while at sea due to defective wiring system which is part of hull & machinery (H&M) risk covered under marine insurance policy. The court held that even though there were no physical injuries suffered by any passenger onboard as result of this accident yet financial losses incurred due to damage or loss of personal belongings are also compensable under doctrine of unseaworthiness since these items are considered necessary adjuncts for purposeful enjoyment during such leisure trips thus forming integral part thereof making them subject matter insured against perils encountered whilst navigating high seas.

In the dissenting opinion for Guzman v. Pichirilo, Justice Harlan argued that the majority's decision to reverse and remand was based on a misinterpretation of both precedent and statutory law. He contended that the court had failed to properly apply the "clearly erroneous" standard of review in assessing whether there was sufficient evidence to support a finding of seaworthiness. According to Justice Harlan, this standard required deference to lower courts' factual findings unless they were clearly unsupported by evidence - which he did not believe was true in this case. Furthermore, he disagreed with the majority's interpretation of The Pennsylvania rule as requiring an automatic presumption against seaworthiness whenever a ship sinks in calm weather without explanation; instead, he believed it merely shifted burden of proof onto defendant once plaintiff made out prima facie case for unseaworthiness claim.