In the case of Ingraham v. United States in 1894, the Supreme Court ruled on a matter concerning maritime law and salvage rights. The dispute arose when two American vessels - one owned by Ingraham and another by the U.S government - both claimed salvage rights over a wrecked Spanish ship off the coast of Florida. Under international law, whoever recovers property from a shipwreck is entitled to compensation (salvage) from its owner. Both parties argued that they were first at the scene and thus had rightful claim to any potential rewards for salvaging goods or materials from this vessel. The court ultimately sided with Ingraham, ruling that his crew was indeed first on site and therefore held priority over any salvage claims related to this particular incident. This decision upheld traditional principles of maritime law which prioritize "first come, first served" in matters relating to marine recovery efforts.

In the dissenting opinion for Ingraham v. United States, Justice Brewer argued that the majority's interpretation of the law was incorrect and overly broad. He contended that a person should not be held criminally liable for actions taken while serving in an official capacity unless there is clear evidence of malicious intent or gross negligence. According to him, this standard protects public officials from frivolous lawsuits and ensures they can perform their duties without fear of legal reprisal. Furthermore, he believed that holding individuals responsible for mistakes made in good faith would deter competent people from seeking public office or accepting government appointments. Ultimately, Justice Brewer felt the court’s decision could have negative implications on effective governance.