In the case of James Shewan & Sons, Inc. v. United States (1924), the Supreme Court ruled on a dispute regarding customs duties imposed on imported goods used in ship repair work by James Shewan & Sons, Inc., a New York-based company. The company argued that it was exempt from paying these duties under an 1866 law which stated that materials for use in repairing American vessels were not subject to import taxes if those repairs took place outside U.S territory and then returned home. However, the government contended this exemption did not apply as the ships were repaired within U.S waters using foreign-sourced materials. The Supreme Court sided with the government's interpretation of the law, ruling against James Shewan & Sons, Inc.. They held that since all repairs occurred within domestic waters rather than abroad as specified by statute language; therefore no tax exemption could be claimed regardless of where parts originated from or whether they had been previously exported before being re-imported for use in such works.

In the dissenting opinion for James Shewan & Sons, Inc. v. United States, Justice McReynolds disagreed with the majority's interpretation of the term "vessel" in Section 3 of The Act to Promote Safety at Sea (1915). He argued that a dry dock should not be classified as a vessel under this act because it was not designed or used for carrying goods or passengers over water like traditional vessels such as ships and boats. Instead, he contended that dry docks are stationary structures primarily used for repairing and building other vessels rather than maritime transportation themselves. Therefore, according to Justice McReynolds' view, they should fall outside the scope of legislation aimed at promoting safety on moving sea-going crafts.