In the 1993 case of Albert Howlett v. Birkdale Shipping Co., S.A., the U.S Supreme Court ruled in favor of Birkdale, a foreign corporation. The issue at hand was whether federal courts had jurisdiction over cases involving international maritime law when no other federal claim was present. Howlett, an American stevedore injured while unloading a ship owned by Birkdale, sued for damages under Florida's long-arm statute and general maritime law. However, because there were no other grounds for federal jurisdiction apart from admiralty (maritime), the District Court dismissed his suit based on forum non conveniens - essentially stating that it would be more appropriate to try this case elsewhere due to its international nature. The Eleventh Circuit reversed this decision but upon reaching the Supreme Court, they affirmed the original dismissal by District court with a unanimous vote (9-0). The court held that even though admiralty claims do not require complete diversity between parties or meet minimum amount-in-controversy requirement like typical civil suits do; they still must have some basis in either constitutionally enumerated powers or congressionally granted authority to fall within federal jurisdiction.

In the dissenting opinion for Albert Howlett v. Birkdale Shipping Co., S.A., 1993, it was argued that the majority's decision to allow a state court to impose sanctions on an attorney who had removed a case from state court to federal court was incorrect. The dissenters believed this ruling violated the Supremacy Clause of the U.S Constitution which establishes that federal law takes precedence over state laws and constitutions when there is conflict between them. They contended that once a case has been moved into federal jurisdiction, only federal courts should have authority over all aspects of it including imposing sanctions on attorneys involved in such cases. This view holds that allowing states' control in these circumstances undermines uniformity in national law and disrupts balance between state and federal judicial systems.