In the case of Inter-Island Steam Navigation Company, Limited v. Ward (1916), the U.S Supreme Court ruled in favor of Ward, who was injured while working on a ship owned by Inter-Island Steam Navigation Company. The court held that under maritime law, an employer is liable for injuries suffered by its employees due to unsafe conditions aboard a vessel even if they were unaware of such conditions. This ruling established the principle that employers have a duty to ensure safe work environments for their employees and can be held responsible when they fail to do so.

In the dissenting opinion for INTER-ISLAND STEAM NAVIGATION COMPANY, LIMITED, v. WARD (1916), Justice Holmes disagreed with the majority's ruling that a ship owner could be held liable for injuries sustained by an employee due to defective equipment on board. He argued that it was not fair or reasonable to hold employers responsible for accidents resulting from faulty machinery unless they had prior knowledge of its condition and failed to rectify it. According to him, this would place an undue burden on businesses and potentially stifle economic growth as companies might become overly cautious in their operations out of fear of litigation. Furthermore, he contended that such liability should only apply if there was a breach of contract between employer and employee regarding safety measures - something which did not exist in this case.