In the case of Hamburg-American Line Terminal & Navigation Company v. United States, 1927, the Supreme Court ruled in favor of the U.S government. The dispute arose over a fine imposed on Hamburg-American for violating immigration laws by allowing an immigrant to enter without proper documentation. The company argued that it had no knowledge or reason to suspect that one passenger's passport was fraudulent and therefore should not be held responsible for his illegal entry into America. However, the court upheld that under existing legislation (the Immigration Act of 1917), ship companies were liable if they transported undocumented immigrants regardless of whether they knew about their status or not. This ruling reinforced strict liability principles within immigration law and emphasized carriers' responsibility in preventing unlawful migration.

In the dissenting opinion for Hamburg-American Line Terminal & Navigation Company v. United States, Justice Holmes argued that the company should not be held liable for damages caused by a fire on one of its ships while it was docked in New York Harbor. He contended that the government had failed to prove negligence on part of the company and thus, it could not be held responsible under maritime law. Furthermore, he believed there was no evidence to suggest that any actions or omissions by employees led directly to the fire's outbreak. Instead, he suggested that other factors such as weather conditions might have contributed significantly towards causing this incident which were beyond control of anyone aboard ship at time when disaster struck.