In the case of Inter-Island Steam Navigation Company, Limited v. Byrne in 1915, the U.S Supreme Court ruled on a dispute involving maritime law and personal injury. The plaintiff, Byrne, was injured while working as a stevedore for the defendant company when he fell through an open hatchway that had been left unguarded. He sued for damages under general maritime law and Hawaiian territorial statutes which required safe conditions for workers aboard ships docked at Hawaiian ports. The lower courts awarded him compensation but this decision was appealed by his employer to the Supreme Court. The central issue before the court was whether federal or local laws should apply in such cases where injuries occur onboard vessels operating between different territories of United States (in this case Hawaii). The court held that federal maritime law applied exclusively to such interstate commerce matters rather than local laws of individual states or territories. Therefore, it overturned previous rulings awarding damages based on violation of specific safety provisions under Hawaiian statute because these were not recognized under general maritime law which only provided remedies for negligence proven against ship owners/operators.

In the dissenting opinion for INTER-ISLAND STEAM NAVIGATION COMPANY, LIMITED, v. BYRNE (1915), Justice Holmes disagreed with the majority's decision to hold a steamship company liable for injuries sustained by an employee during his off-duty hours while on board the ship. He argued that it was unreasonable to expect employers to provide absolute safety for their employees at all times and in every circumstance. According to him, there should be a clear distinction between risks associated with work duties and those arising from personal activities or choices made outside of work responsibilities. In this case, he believed that Byrne's injury resulted from his own actions rather than any negligence on part of the employer; hence, no liability should be imposed upon Inter-Island Steam Navigation Company.