In the case of Jerome B. Grubart, Inc. v. Great Lakes Dredge & Dock Company et al., 1994, the U.S Supreme Court ruled in favor of Great Lakes Dredge & Dock Co., affirming that federal admiralty jurisdiction applied to their situation under both location and connection tests established by previous rulings (the "Sisson" test). The dispute arose when work done by Great Lakes on a river caused damage to buildings owned by Grubart through flooding from increased water pressure underground. Grubart sued for damages in state court but Great Lakes sought to move proceedings into federal court due its maritime nature as they were executing a contract with the city of Chicago involving navigable waters which was potentially disruptive to maritime commerce if not properly managed or executed. The District Court agreed with this argument and moved it into Federal Admiralty Jurisdiction; an appeal affirmed this decision leading up-to-the Supreme Court where it was upheld.

In the dissenting opinion for Jerome B. Grubart, Inc. v. Great Lakes Dredge & Dock Company et al., Justice Thomas, joined by Justice Scalia, argued that the majority's decision expanded federal admiralty jurisdiction beyond its historical boundaries and intent of the framers of the Constitution. They contended that this case did not meet either prong of a two-part test established in previous court decisions to determine whether an incident has sufficient connection with maritime activity to warrant federal jurisdiction: it must have a potentially disruptive impact on maritime commerce and be substantially related to traditional maritime activity. The justices believed that pile driving (the action causing damage) is not inherently a maritime activity as it can occur both on land or water; thus, they disagreed with categorizing all pile-driving incidents occurring on navigable waters under admiralty jurisdiction regardless of their nature or potential effect on navigation.